CCTV, Personal Data, and your rights: Employers and Employees
CCTV offers palpable benefits for you as an employer and perhaps most significantly for your employees. Feeling safe at work has been connected to increased productivity and a thriving work community and culture, (See connected blog here).
Though, perhaps like anything, it is important to understand your rights and responsibilities and also the rights of your employees when it comes to installing CCTV. In 2015 The Data Protection Commissioner in Ireland issued new and updated guidelines in respect to the use of CCTV on your property, and here are 3 important aspects of that update that you have to keep in mind when installing a CCTV system in a work environment.
A) Justification and Proportionality
– When installing a new CCTV system, you must be able to justify the use and proportionality of that system. Don’t fret ! For the most part, this isn’t a terribly difficult. The benefits of CCTV for security and safety are overwhelming, particularly when it comes to the security of your premises and property. This being said, the Data Protection Commissioner has defined CCTV as the collection of ‘personal data’ and therefore this collection must be justified and organised proportionally to your space. For instance, CCTV that is focused solely on employees may be more difficult to justify than if you spread the cameras out around the property to cover all aspects of the property.
– It is also important to note that once the installation of the CCTV system has been put in place, warnings have to be given to Data Subjects. I.e., you have to ensure that people are aware that they’re being recorded. According to the Data Commissioner, if the reason for the cctv is obvious, a sign that makes people aware that cctv is in operation and has a contact phone number, is sufficient. At Rath Security, with the installation of CCTV we supply signs like the ones below so that the warning is clear and obvious to visitors and employees alike. It is vital to note though, that if the cctv is installed to manage staff performance and not solely for safety or security, you must verbally make individuals aware of the cameras in place. We at Rath would also recommend that written signs stating the presence of CCTV also be put in place throughout the office for added coverage.
C) Written Policy
– Once CCTV has been installed and warning signs have been placed, it is important to create a written CCTV policy that you have on hand for reference and that is available to your staff. The written policy should include the following; 1) The identity of the data controller, 2) The purpose of the data processing, 3)Any 3rd parties to whom it is made available, 4) How to make an access request, 5) The retention period of the CCTV and 6)The security arrangements for the CCTV. A general rule of thumb related to retention period is that data should not be held for over a month once recorded.
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