CCTV Policy

Overview

Complete Dentistry uses closed circuit television (CCTV) images for the prevention, identification and reduction of crime and monitor the practice premises in order to provide a safe and secure environment for staff and visitors, and to prevent the loss or damage to property.

CCTV surveillance at the premises is intended for the purposes of:

• reducing the incidence of crime and anti-social behaviour, including verbal/physical abuse, theft and vandalism
• assisting in identifying offenders
• promoting the health and safety of staff and patients
• protecting the building and practice assets, both during and after business hours

The system comprises of 6 fixed cameras, 2 of which have sound. The CCTV system is owned and operated by Complete Dentistry and involves recording.

All authorised employees with access to images are aware of the procedures that need to be followed when accessing the recorded images. Those employees are aware of the restrictions in relation to access to, and disclosure of, recorded images.

The use of the CCTV system will be conducted in a professional, ethical and legal manner and any diversion of the use of CCTV security technologies for other purposes is prohibited by this policy e.g. CCTV will not be used for monitoring employee performance.

CCTV monitoring of public areas for security purposes will be conducted in a manner consistent with all existing policies.

Justification for Use of CCTV
The use of CCTV to control the premises for security purposes has been deemed to be justified by the premise’s owners. The system is intended to capture images of anti-social or threatening behaviour, intruders or of individuals damaging property or removing goods without authorisation.

Location of Cameras
Cameras have been sited so they only capture images relevant to the purposes for which they are installed, and care will be taken to ensure that reasonable privacy expectations are not violated.

The practice owner will ensure that the location of equipment is carefully considered to ensure that images captured comply with the Data Protection Act. CCTV will not be used in private or personal rooms/areas. CCTV Video Monitoring and Recording of Public Areas may include the following:

• Protection of staff, buildings and property: The practice’s reception and waiting areas, entrances and exits and corridors
• Criminal Investigations (carried out by police): Robbery, burglary and theft surveillance

Covert Surveillance
Complete Dentistry will not engage in covert surveillance.

Notification
A copy of this CCTV Policy will be provided on request to staff, patients and visitors to the Complete Dentistry. Signage has been placed at the practice to indicate that CCTV is in operation and includes the name and contact details of the data controller.

Storage and Retention
The images captured by the CCTV system will be retained for a maximum of 60 days, except where the image identifies an issue and is retained specifically in the context of an investigation/prosecution of that issue. The images/recordings will be stored in a secure environment with a log of access kept. Access will be restricted to authorised personnel. Supervising the access and maintenance of the CCTV System is the responsibility of the practice owner. The practice owner may delegate the administration of the CCTV System to another staff member. In certain circumstances, the recordings may also be viewed by other individuals in order to achieve the objectives set out above. When CCTV recordings are being viewed, access will be limited to authorised individuals on a need-to-know basis.

Access
Recorded footage and the monitoring equipment will be securely stored in a restricted area. Unauthorised access to that area will not be permitted at any time. The area will be locked when not occupied by authorised personnel. A log of access to footage will be maintained. Access to the CCTV system and stored images will be restricted to authorised personnel only. A record of the date of any disclosure request along with details of who the information has been provided to (the name of the person and the organisation they represent), why they required it and how the request was dealt with will be made and kept, in case of challenge. Data will be provided to those requests authorised in a permanent format where possible. If this is not possible the data subject will be offered the opportunity to view the footage.

In relevant circumstances, CCTV footage may be accessed:

• By the police (or its agents) are required by law to make a report regarding the commission of a suspected crime
• Following a request by the police when a crime or suspected crime has taken place and/or when it is suspected that illegal/anti-social behaviour is taking place on property
• To assist the practice owner in establishing facts in cases of unacceptable behaviour
• To data subjects (or their legal representatives), pursuant to a Subject Access Request
• To individuals (or their legal representatives) subject to a court order
• To the practice insurance company where the insurance company requires same in order to pursue a claim for damage done to the insured property.

Subject Access Requests (SAR)
Individuals have the right to request access to CCTV footage relating to themselves under the Data Protection Act. Individuals submitting requests for access will be asked to provide sufficient information to enable the footage relating to them to be identified. For example, date, time and location. The practice owner will respond to requests within 30 calendar days of receiving the request. The practice owner reserves the right to refuse access to CCTV footage where this would prejudice the legal rights of other individuals or jeopardise an on-going investigation. A record of the date of the disclosure along with details of who the information has been provided to (the name of the person and the organisation they represent) and why they required it will be made. In giving a person a copy of their data, images of other individuals will be obscured before the data is released. Where footage contains images relating to 3rd parties, the premises/system owner will take appropriate steps to mask and protect the identities of those individuals.

Complaints
Complaints and enquiries about the operation of CCTV within the premises should be directed to the practice owner in the first instance.

Staff Training
Staff authorised to access the CCTV system will be trained to comply with this policy. Staff will understand that all information relating to the CCTV images must be handled securely. Staff will receive appropriate training to enable them to identify and handle different requests according to regulations. Staff misuse of surveillance system information will lead to disciplinary proceedings.

Responsibilities
The practice owner (or nominated deputy) will:

• Ensure that the use of CCTV system is implemented in accordance with the policy set down by Complete Dentistry
• Oversee and co-ordinate the use of CCTV monitoring for safety and security purposes within Complete Dentistry
• Ensure that the CCTV monitoring at Complete Dentistry is consistent with the highest standards and protections
• Review camera locations and be responsible for the release of any information or recorded CCTV materials stored in compliance with this policy
• Maintain a record of access (e.g. an access log) to or the release of tapes or any material recorded or stored in the system
• Give consideration to both patient and staff feedback/complaints regarding possible invasion of privacy or confidentiality due to the location of a particular CCTV camera or associated equipment
• Ensure that all areas being monitored are not in breach of an enhanced expectation of the privacy of individuals within the practice and be mindful that no such infringement is likely to take place
• Ensure that monitoring footage are stored in a secure place with access by authorised personnel only
• Ensure that images recorded on tapes/DVDs/digital recordings are stored for a period not longer than 60 days and are then erased unless required as part of a criminal investigation or court proceedings (criminal or civil)
• Ensure that camera control is not infringing an individual’s reasonable expectation of privacy in public areas