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Using CCTV in People’s Homes – Policy and Procedure

1. Introduction

This policy outlines our Home Care Service’s approach to the use of Closed-Circuit Television (CCTV) or other recording devices in the private homes of people who use our service (referred to as “individuals” or “people we support”). It explains how we ensure any CCTV or similar technology is used in a manner that respects privacy and dignity, while also meeting legal and regulatory obligations under the Care Inspectorate Scotland guidelines, data protection law, and other relevant legislation.

We recognise that some individuals, or their families and representatives, may decide to install CCTV or similar recording devices in their homes for the purposes of security, monitoring health and safety, or offering peace of mind. Our aim is to give comprehensive guidance to our staff and clear evidence to Care Inspectorate inspectors on how CCTV usage is managed safely, lawfully, and ethically.

2. Scope

This policy applies to:

• All staff members (including employed and contracted personnel) who may encounter CCTV or other recording devices in an individual’s home.
• Any situation where monitoring devices (audio and/or video) are used in the context of care delivery within an individual’s home.

3. Legal and Regulatory Framework

1. Care Inspectorate Scotland Regulations: Ensuring we meet the Health and Social Care Standards (often referenced as “[SC1]”) regarding privacy, dignity, and respect for individuals.
2. Data Protection Laws: Complying with the requirements of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (“[SC2]”), including proper collection, storage, and usage of personal data.
3. Human Rights Considerations: Respecting the right to privacy under the Human Rights Act 1998 (“[SC3]”).
4. Equality and Non-Discrimination: Acknowledging the Equality Act 2010 to ensure CCTV usage does not discriminate against any protected characteristic.

4. Policy Statement

Our service respects the rights of individuals to install CCTV or other monitoring systems in their homes for the purposes of safety, wellbeing, or reassurance. We also recognise the importance of maintaining the dignity and privacy of those who receive care. Therefore, any use of CCTV in a person’s home must:

• Be guided by informed consent from the individual or their legal representative.
• Protect the privacy of all parties, including visitors and staff.
• Comply with relevant laws and Care Inspectorate Scotland guidance.
• Be proportionate, necessary, and reflect the individual’s best interests.

5. Consent and Best Interests

5.1 Informed Consent

Before any CCTV is used in a person’s home, we expect that the individual (or their legal representative) has been fully informed and has given explicit consent for its use. Staff must:

• Encourage open discussion about why CCTV is being considered, whether it is necessary, and how it may impact privacy.
• Check that the individual understands the scope of CCTV monitoring (e.g., which rooms or areas will be covered).
• Confirm that the individual is aware of how footage will be stored, accessed, and shared.

5.2 Capacity and Best Interests

If the individual does not have the capacity to give informed consent:

• We will work alongside family members or legal representatives (such as those holding Power of Attorney or Guardianship) to ensure decisions about CCTV are made in the person’s best interests.
• We will liaise with relevant health and social care professionals as appropriate, and document all discussions thoroughly.

6. Operational Procedures

6.1 Placement and Coverage of Cameras

We expect individuals or their families to position cameras in a manner that respects privacy. This means:

• Avoiding installation in private areas such as bathrooms or changing areas, unless there is a clear, documented clinical or safety reason.
• Ensuring signage or notices are placed in the home to inform visitors and staff of CCTV presence where feasible (e.g., a simple notice at the entrance to the property).
• Reviewing camera angles regularly to confirm they do not inadvertently capture areas beyond what is necessary.

6.2 Confidentiality of Recordings

Footage captured by CCTV may contain highly sensitive personal information. Therefore:

• Footage should be stored securely, with password protection or other secure access measures in place.
• Access to footage should be limited to authorised persons only (the individual, their nominated representatives, or legal authorities where required).
• Staff members are not permitted to copy, retain, or share any footage without clear, documented authorisation.

6.3 Data Retention

Any recordings stored by individuals or families must be kept for only as long as necessary and then securely deleted. Staff should advise individuals on the importance of:

• Setting data retention periods (e.g., 14, 30, or 60 days) as appropriate.
• Reviewing recordings to delete or archive them in a secure manner.

6.4 Access Requests

On occasion, care staff or the service may request to view footage to address a complaint or investigate an incident. Any such request must:

• Be made formally and in writing to the individual or their representative.
• Clearly outline the purpose of viewing the footage.
• Only proceed if permission is granted by the individual or their representative.

7. Safeguarding and Incident Reporting

If CCTV footage reveals a safeguarding concern or incident that requires further investigation or reporting:

1. Immediate Action: Staff must follow the organisation’s Safeguarding Policy and contact a manager or safeguarding lead at once.
2. Preservation of Evidence: The relevant footage (and any back-up copies) must be secured to prevent tampering or accidental deletion.
3. Reporting: Notify the Care Inspectorate Scotland and any other relevant authorities according to local procedures if the concern meets reporting thresholds.

8. Staff Responsibilities and Training

8.1 Staff Conduct

All staff must respect that there may be CCTV in place when they are delivering care. This means:

• Maintaining professionalism at all times.
• Delivering care in line with the individual’s care plan and safeguarding their privacy (e.g., closing doors or curtains during personal care, even if there is CCTV in the room).
• Being alert to signs that an individual is uncomfortable or distressed by the CCTV and reporting these concerns to their line manager.

8.2 Training and Awareness

We ensure that staff have a clear understanding of our policy on CCTV by:

• Including a dedicated session in our induction and refresher training programmes on privacy, dignity, and the appropriate use of CCTV.
• Providing updates on any changes in legislation or best practice.
• Making sure staff know how to advise individuals or families on the responsible and respectful use of CCTV if asked.

9. Monitoring and Compliance

9.1 Regular Review

Our Home Care Service will periodically review how CCTV is being used within individuals’ homes where relevant. This review may involve:

• Seeking feedback from staff, the individuals, and their families about the appropriateness of CCTV usage.
• Checking if any recorded incidents or issues indicate a need to adjust or remove cameras.
• Ensuring data protection obligations (e.g., data retention) are still being followed effectively.

9.2 Audit Trail and Documentation

• All discussions regarding the decision to use CCTV, including consent forms and risk assessments, must be documented in the individual’s care plan or support records.
• Any incidents relating to CCTV use (including complaints or disputes) are logged as part of our internal quality assurance processes and reported to the Care Inspectorate Scotland where required.

10. Complaints and Concerns

If individuals, staff, or visitors have any concerns or wish to make a complaint about the use of CCTV, they should be encouraged to:

• Raise their concern with the manager of our Home Care Service, who will investigate in line with our Complaints Procedure.
• Contact the Care Inspectorate Scotland if they feel their concern remains unresolved or they wish to escalate it.

11. Review of this Policy

This policy will be reviewed annually or sooner if there are significant changes in legislation or best practice guidance. Any amendments will be communicated promptly to all staff members, and relevant training will be provided to ensure continued compliance.

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