CCTV Policy

The use of closed-circuit television at Westwood Smile Care Ltd aims to comply with the UK General Data Protection Regulation, Data Protection Act 2018, the ICO data protection code of practice for surveillance cameras and personal information and with the GDC Standards.

This policy is reviewed on an annual basis and should be read in conjunction with the Data Protection Policy (M 233-DPT). The CCTV system and the images produced by it are managed by the Practice Manager, Dolly Dandridge. The data controller is Dr Aman Ruprah.

CCTV has been installed in the practice after taking advice and justification of CODE. They advise that due the the ECHR ruling regarding the ‘human right to respect for private life’ it is necessary to justify the installation of cameras here in the practice. For the safety of our patients and our staff, the Management is aware of an increase in incidents of violence, aggression and theft in the reception areas. CCTV also monitors our entrances and exits for additional security of our building and the car park area for our patients and staff parking.

The Practice Management has considered whether any other methods would be suitable to meet this need and decided that CCTV is the best solution under the circumstances. We carry out an annual review of our decision and the system chosen, using our Annual CCTV Checklist (M 216B). We DO NOT record in the clinical surgeries, patient consultations or treatments, as the ethical and consent considerations for this are complex and we understand the need for our patients to have a high degree of privacy during their treatment.

Images captured with CCTV are kept securely and automatically destroyed after 2 months. Images will only be used for the purposes for which they have been collected. However, it may be necessary to use the information recorded on our CCTV to assist with a disciplinary investigation where there is a justifiable business case to do so. This is explained to our staff in our staff handbook and at the interview stages of their recruitment process.

CCTV cameras which record data in the practice, are located in and cover the following areas:

Camera 1 – Front LHS Car Park, Camera 2 – Front RHS Car Park, Camera 3 – Waiting Room, Camera 4 – Reception, Camera 5 – Side Entrance, Camera 6 – Rear Garden, Camera 7 – Staff Room, & Camera 8 – Managers Office

The Practice Manager Dolly Dandridge is responsible for Managing the CCTV system, the camera system has been chosen to produce clear images that reduce any privacy risks. Cameras have been sited with consideration to producing clear images and to avoid capturing images of persons not visiting the practice. The cameras are not capable of recording sound.

There are clear visible signs showing that CCTV is in operation both in the practice and on our website, for the purpose of crime prevention and who is responsible for the recording. Images from the CCTV system are securely stored for 60 days, to allow any incidents to come to light and be fully investigated. Following this period the images are automatically permanently erased. Only the practice Owner, Dr Aman Ruprah and the Practice Manager have authorised secure access.

Requests by third parties, such as the police or solicitors, should be submitted in writing. The practice will then:

• Verify the identity of the person/organisation and take a copy of any identification documents, if required
• Decide whether providing the CCTV recording would satisfy one or more of the reasons listed in this policy
• Consider the rights of the individuals shown in the CCTV and balance the protection of these rights against the reasons for the request. Some images may require editing to protect individuals’ privacy
• Securely transfer the requested CCTV recordings/images to the third party if appropriate
• Keep a record of the disclosures of CCTV to the third party