The use of closed circuit television at myFACE aims to comply with the Data Protection Act (1998), the ICO CCTV Code of Practice (2008) and with GDC Standards. This policy is reviewed on an annual basis and should is read in conjunction with the Data Protection Policy (M 233-DPT). The CCTV system and the images produced by it are managed by the Data Controllers Tim and Lydia Eldridge.
CCTV has been installed in the practice for purposes of patient, staff and premises security and to monitor trespassing.
Practice management has considered whether any other methods would be suitable to meet this need and decided that CCTV is the best solution. We carry out an annual review of our decision and system chosen using the Annual CCTV Checklist (M 216B). We do not record patient consultations or treatment as the ethical and consent considerations are complex and patients expect a high degree of privacy during treatment.
Images captured with CCTV will be kept securely and destroyed securely after one month. Images will only be used for the purposes for which they have been collected and can be kept for longer in some circumstances e.g. crime prevention. However, it may be necessary to use information recorded on CCTV to assist with a disciplinary investigation where there is a clearly justifiable business case to do so.
CCTV cameras, which record data in the practice, are located in and cover the following areas:
- Reception, mainly focused at the front door.
- Ground level, to monitor access to the building.
- Basement, to monitor access to the building.
- Car park, to monitor access and trespassing.
To meet requirements:
The Data Controller is responsible for managing the CCTV system
The data collected is fairly and lawfully processed, processed for limited purposes, adequate, relevant and not excessive, accurate, not kept for longer than necessary and is processed in accordance with individual rights,
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. The cameras do not record sound.
There are clearly visible signs showing that CCTV is in operation for the purpose of crime prevention and who is responsible for the recording
Images from the CCTV system are securely stored for one months, to allow an incident to come to light and be investigated. Following this period the images are permanently erased from the storage device.
Images are captured 24 hours a day, seven days a week.
Only the Practice Owners Tim Eldridge and Lydia Eldridge (Data Controllers) and Practice Manager Charlotte Bamford are authorised to have access to the images.
Images will not be disclosed to third parties except to police when a suspected criminal offence has been committed
The practice will respond to subject access requests from individuals for copies of their own images as described in our data protection policy (M 233-DPT).
The CCTV system is regularly checked to ensure that it is working properly and capturing clear images.
Visitors to the practice have the right to request to see images of themselves on CCTV as part of a date request. Please make your request in writing to the practice manager Charlotte Bamford on firstname.lastname@example.org or myFACE, 4 Suffolk Road, Cheltenham, GL50 2AQ. We will also require information that will allow us to identify the visitor and the date/time of the visit. There is no charge for this service unless there is an exceptional level of data required. The practice manager will acknowledge the request within 3 working days and respond to the request within 4 weeks. myFACE reserves the right to withhold footage where other clients/third parties can be identified.