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CCTV/WebCam Surveillance

Personal Data, in DPA terms, includes any image from which an individual may be identified. The processing of personal data includes the recording, viewing, storage, and destruction of the personal data.

CCTV and WebCam type surveillance systems are operated by the University for the purposes of safety, security, and detection of crime. Such operations are within the scope of the DPA where images are collected and/or displayed and/or stored for those purposes and where the image resolution is such that individuals may be identified. As the processing of personal data requires the consent of the individual, it is essential that visible warning signs [preferably incorporating an image of a CCTV camera] are provided so that people are aware they are entering an area covered by surveillance equipment.

CCTV & WebCam type surveillance systems that (a) do not record images, or (b) where individuals cannot be identified from the images, are outwith the scope of the DPA. It is not recommended that a CCTV type system that does not meet this criteria is identified as covered by the DPA as this could be considered as misleading and potentially in breach of the DPA.

The UK Information Commissioner, as the regulator of the Data Protection Act, has produced an updated 2008 edition of the comprehensive CCTV Code of Practice.

The use of CCTV and WebCam type systems for targeted and/or covert surveillance activities are outwith the scope of this guidance. Targeted surveillance is covert, but not intrusive, where it is undertaken for the purposes of a specific investigation and in such a manner as is likely to result in the obtaining of private information about a person; Covert surveillance is carried out in a manner calculated to ensure that the subject of the surveillance is unaware that it is, or may be, taking place.  The UK Information Commissioner, as the regulator of the Data Protection Act, has also produced a comprehensive Employment Practices Code plus Supplementary Guidance that covers, amongst other issues, monitoring.