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Use of CCTV and Surveillance in Care Homes Policy

1. Purpose

This policy outlines the lawful, ethical, and transparent use of Closed-Circuit Television (CCTV) and surveillance within our care home to protect the safety, dignity, and privacy of the people we support, staff, visitors, and property. CCTV must be used in full compliance with CQC regulations, the Data Protection Act 2018, the UK General Data Protection Regulation (UK GDPR), the Human Rights Act 1998, and the Surveillance Camera Code of Practice (2013). It also ensures that surveillance is proportionate, necessary, and justifiable, balancing safety needs with personal privacy. This policy aligns with Regulation 10 – Dignity and Respect​, Regulation 12 – Safe Care and Treatment​, and Regulation 17 – Good Governance​.

2. Scope

This policy applies to:

• All CCTV and other forms of surveillance used within the care home, including audio recording devices, motion sensors, and covert surveillance (only where legally justified).
• The people we support, staff, visitors, and contractors who may be recorded.
• The collection, processing, storage, and sharing of video footage.
• The lawful basis for using CCTV, including consent, security, and safeguarding concerns.

3. Related Policies

• CH04 – Good Governance Policy (Ensuring lawful and ethical use of surveillance).
• CH08 – Dignity and Respect Policy (Protecting the privacy and dignity of individuals).
• CH13 – Safeguarding Adults from Abuse and Improper Treatment Policy (Preventing abuse while ensuring fair surveillance practices).
• CH34 – Confidentiality and Data Protection (GDPR) Policy (Managing access to surveillance footage securely).
• CH35 – Duty of Candour Policy (Ensuring transparency when disclosing surveillance recordings related to incidents).
• CH42 – Communication and Engagement with Service Users and Families Policy (Ensuring informed consent and clear communication about CCTV use).

4. Legal and Ethical Considerations

• The use of CCTV must be justified and proportionate – Surveillance must only be used where necessary, such as for security, safeguarding, or preventing crime. It must not be used to monitor staff performance unless required for specific investigations.
• Consent and Transparency – People we support, staff, and visitors must be fully informed of any surveillance in place. Clear signage must be displayed, and consent must be obtained where required.
• Data Protection and GDPR Compliance – CCTV recordings are personal data and must be managed in accordance with UK GDPR and Data Protection Act 2018. Only authorised personnel can access footage.
• Respect for Privacy and Dignity – Surveillance must not be installed in private areas such as bedrooms, bathrooms, or staff rest areas unless legally justified and with explicit consent.
• The Human Rights Act 1998 – Ensures that CCTV usage does not infringe on the right to privacy (Article 8).
• Covert Surveillance – Only permissible under exceptional circumstances (e.g., serious safeguarding concerns), following strict legal procedures and involvement of external authorities.

5. Justification for CCTV Use

CCTV is implemented for the following reasons:

• Enhancing security – Protecting people we support, staff, and visitors from crime or unauthorised entry.
• Safeguarding vulnerable individuals – Monitoring communal areas to help prevent abuse or neglect.
• Incident investigation – Supporting investigations into falls, accidents, or allegations of misconduct.
• Property protection – Preventing theft, vandalism, or damage to the premises.

CCTV must never be used as a substitute for quality care or supervision.

6. CCTV Placement and Usage

CCTV may be installed in:

• Entrances and exits to monitor people entering and leaving the care home.
• Communal areas such as lounges, dining areas, and hallways.
• Outdoor areas and car parks to ensure security.
• Staff-only areas (where justified) to protect sensitive locations such as medication storage areas.

CCTV must not be placed in:

• Bedrooms or private spaces, unless there is an overwhelming safety justification and explicit written consent.
• Toilets and bathrooms under any circumstances.
• Staff break rooms, ensuring privacy and dignity for employees.

7. Consent and Informing Stakeholders

• People we support, their families, and visitors must be informed about CCTV usage via:
  • Signage in key locations.
  • Admission discussions with new residents and their representatives.
  • Consent forms where necessary.
• Staff must be informed of:
  • Where CCTV is used and why.
  • Their rights regarding surveillance.
  • The process for accessing recorded footage.

If a person we support lacks capacity, CCTV use must be assessed under the Mental Capacity Act 2005, ensuring decisions are in their best interests.

8. Access to CCTV Footage and Data Security

• Only authorised personnel (e.g., Registered Manager, Data Protection Officer) may access CCTV recordings.
• CCTV data must be:
  • Stored securely on encrypted systems.
  • Retained for a maximum of 30 days, unless required for an ongoing investigation.
  • Not shared with unauthorised parties without consent or a legal basis.
• If required for police investigations, safeguarding inquiries, or CQC inspections, footage may be shared under strict security measures.

9. Surveillance in Safeguarding Investigations

• If abuse or neglect is suspected, CCTV footage can support investigations, but must be used ethically and within legal frameworks.
• Covert surveillance may only be used:
  • Where there is strong evidence of harm.
  • After consultation with legal and safeguarding authorities.
  • In compliance with the Regulation of Investigatory Powers Act 2000 (RIPA).
• Any incidents identified via CCTV must be reported, following safeguarding procedures and CQC requirements.

10. Handling Requests for CCTV Footage

• Individuals can request access to footage featuring themselves under UK GDPR (Subject Access Requests).
• Requests must be made in writing to the Data Protection Officer and will be processed within one month.
• Third-party access (e.g., police, legal representatives) must be assessed under data protection laws.

11. Complaints and Disputes Regarding CCTV

• Complaints about CCTV usage should be raised with the Registered Manager under the CH14 – Receiving and Acting on Complaints Policy.
• If unresolved, concerns can be escalated to the Information Commissioner’s Office (ICO) or CQC.

12. Staff Training and Compliance

• All staff must complete mandatory training on:
  • The legal and ethical use of CCTV.
  • Data protection and GDPR compliance.
  • The rights of people we support regarding surveillance.
• Regular compliance audits will be conducted to ensure adherence to this policy.

13. Policy Review

This policy will be reviewed annually or sooner if there are changes in legislation, best practices, or operational requirements. Updates will be made to reflect CQC guidance, ICO recommendations, and advancements in data security measures.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
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