Mandley Park Dental Practice CCTV Policy

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Introduction

Mandley Park Dental Practice, hereafter referred to as “The Practice” operates a closed-circuit television (CCTV) system to protect property and to provide a safe and secure environment for employees, clients, customers and visitors to the Practice’s business premises. This policy sets out the details of how the Practice collects, uses and stores CCTV recordings. For more information on the privacy rights associated with the processing of any personal data collected through CCTV imaging please refer to the Company privacy notice and data protection policy. The Company’s CCTV system, unless there are exceptional circumstances, (see Covert Recording below), will only record images.  There is no audio recording i.e. conversations are not recorded on CCTV.

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Purposes of CCTV

The Practice has carried out a data protection impact assessment (DPIA) and based on the findings, considers it necessary and proportionate to install and use a CCTV system. Data collected from the system will assist in:

• Monitoring of the security of the Practice’s business premises.

• Ensuring health and safety rules and Practice procedures are being complied with.

• Identification of unauthorised actions or unsafe working practices

• As an aid to increased productivity and efficiency.

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Location of cameras

Cameras are located at strategic points throughout the Practice’s business premises. The Practice has positioned the cameras so that they only cover communal or public areas on the Practice’s business premises and they have been sited so that they provide clear images.  No camera focuses, or will focus, on toilets, changing rooms, or staff break rooms.

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Visibility of cameras.

Appropriate signs are prominently displayed so that employees, clients, customers, and other visitors are aware they are entering an area covered by CCTV. Patients are explicitly made aware of CCTV being in place in the surgeries and can request to it being switched off for the duration of their time in the surgery.

Recording and retention of images

Images produced by the CCTV equipment are intended to be as clear as possible so that they are effective for the purposes set out above. Maintenance checks of the equipment are undertaken on a regular basis to ensure it is working properly and that the media is producing high quality images.

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Normal Operation

The CCTV system has several modes of operation, in normal operation two modes are used:

During the time the Practice’s is open,

The CCTV is used for live viewing of real time images with no audio recording. The Practice’s camera system allows for recording of audio, but this feature is not enabled.

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 During the time the Practice is closed

 The CCTV system operates in security mode: the cameras record any movement detected by the cameras for the duration of the time that the movement is within a camera’s view. In this mode CCTV images are stored and are held on a cloud-based server. The images are deleted after one month.

Changes to system operation in exceptional circumstances

The Practice reserves the right to temporarily alter the use of the CCTV system as part of any investigation undertaken into suspected malpractice or criminal act(s) at the practice. The extent and period of the change and safeguards employed are set out in this policy (see Covert Recordings). In this case CCTV images and audio monitored during opening hours may be recorded and stored.

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Access to and disclosure of CCTV Data

Access to images and recordings

• Access to, and disclosure of, images recorded on CCTV is restricted.  This ensures that the rights of individuals are retained.

• Images can only be disclosed in accordance with the purposes for which they were originally collected. 

• Access to recorded images is restricted to those who are authorised to view them in accordance with the purposes of the system.  Viewing of recorded images will take place in a restricted area to which other employees will not have access when viewing is occurring.   

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Disclosure of CCTV Data to Third Parties

Disclosure of images to other third parties will only be made in accordance with the purposes for which the system is used and will be limited to:

The police and other law enforcement agencies, where the images recorded could assist in the prevention or detection of a crime or the identification and prosecution of an offender or the identification of a victim or witness.

• Prosecution agencies, such as the Crown Prosecution Service.

• Relevant legal representatives.

• Line managers involved with Company disciplinary and performance management processes.

• Individuals whose images have been recorded and retained (unless disclosure would prejudice the prevention or detection of crime or the apprehension or prosecution of offenders).

Tasja Villegas is the only person who is permitted to authorise disclosure of images to external third parties such as law enforcement agencies.

All requests for disclosure and access to images will be documented, including the date of the disclosure, to whom the images have been provided and the reasons why they are required.  If disclosure is denied, the reason will be recorded.

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Individuals’ access rights

Under the UK’s data protection laws, including the General Data Protection Regulation (GDPR), individuals have the right on request to receive a copy of the personal data that the Practice holds about them, including CCTV audio and images if the individual is recognisable from the image. 

Any Individual who wishes to access any CCTV images relating to them, must make a written request to Tasja Villegas. This can be done by using this email address mandleyparkdental@gmail.com.  The Practice will usually not make a charge for such a request, but may charge a reasonable fee for any request which is manifestly unfounded, excessive or repetitive. Any request must include the date and approximate time when the images were recorded and the location of the particular CCTV camera, to identify and locate the images, and establish the  identity of the person in the images’

The Practice will usually respond promptly within one month of receiving a request. Where a request is complex or numerous the Practice may extend the one month to respond by a further two months.

The Practice will always check the identity of the individual making the request before processing it.

Tasja Villegas will always determine whether disclosure of images requested by an individual will reveal third party information, as there is  no right to access to CCTV images relating to other persons.  In this case, any images of third parties, computer screens or paper records visible on the CCTV images will be obscured if it would otherwise involve an unfair intrusion into their privacy.

If the Practice is unable to comply with your request because access could prejudice the prevention or detection of crime or the apprehension or prosecution of offenders, you will be advised accordingly.

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Covert recording

The Practice is aware that covert recording can only be done in exceptional circumstances. The Practice will only undertake covert monitoring if it has carried out a data protection impact assessment specific to the exceptional circumstance which has addressed the following:

• the purpose of the covert recording.

• the necessity and proportionality of the covert recording.

• the risks to the privacy rights of the individual(s) affected by the covert recording.

• the time parameters for conducting the covert recording

• the safeguards and/or security measures that need to be put in place to ensure the covert recording is conducted in accordance with the data protection laws, including the GDPR.

Where practicable Tasja Villegas will assign an investigating officer to undertake a data impact assessment. If after undertaking the data impact assessment the Practice considers there is a proportionate risk of criminal activity, or equivalent malpractice taking place or about to take place, and if informing the individuals concerned that the recording is taking place would seriously prejudice its prevention or detection, the Practice will covertly record the suspected individual(s). In doing this the Practice will rely on the protection of its own legitimate interests as the lawful and justifiable legal basis for carrying out the covert recording.

Before the covert recording commences the Practice will ensure that Tasja Villegas agrees with the findings of the data protection assessment and provides written authorisation to proceed with the covert recording. Depending on the nature of the exceptional circumstances in relation to the size of the practice Tasja Villegas may undertake the role of both investigating officer and authorising authority   

Covert monitoring may include both video and audio recording.

Covert monitoring will only take place for a limited and reasonable amount of time consistent with the objective of assisting in the prevention and detection of particular suspected criminal activity or equivalent malpractice.  Once the specific investigation has been completed, covert monitoring will cease.

Information obtained through covert monitoring will only be used for the prevention or detection of criminal activity or equivalent malpractice.  All other information collected in the course of covert monitoring will be deleted or destroyed unless it reveals information which the Practice cannot reasonably be expected to ignore.

Implementation

Tasja Villegas is responsible for the implementation of and compliance with this policy and the operation of the CCTV system and will conduct a regular review of the Practice’s use and processing of CCTV and ensure that at all times it remains compliant with the laws regulating data protection and privacy. Any complaints or enquiries about the operation of the Practice’s CCTV system should be addressed to Tasja Villegas.

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Staff training

Access to the Practice’s CCTV system is restricted to authorised members of staff. The Practice will ensure that any employees handling CCTV images or recordings are trained in the operation and administration of the CCTV system and on the impact of the laws regulating data protection and privacy with regards to the system. 

Data Protection

We have followed the CCTV guidelines produced by the Information Commissioners’ Office, http://www.ico.org.uk/for_organisations/data_protection throughout.

The Practice will process the personal data collected in connection with the operation of the CCTV policy in accordance with its data protection policy and any internal privacy notices in force at the relevant time. Inappropriate access or disclosure of this data will constitute a data breach and should be reported immediately to Tasja Villegas in accordance with the Practice’s data protection policy. Reported data breaches will be investigated and may lead to sanctions under the Practice’s disciplinary procedure.

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Next review 03/2023

March 2022, TV