According to the Information Commissioner for England's website, the UK has more closed circuit television (CCTV) cameras per person than anywhere else in the world. Practices are adding to this tally and must meet a range of requirements to ensure they do so legally.
Use of CCTV
The Information Commissioner's CCTV Code of Practice 2008 requires organisations to consider whether CCTV is the most appropriate tool before installing it.
For example, if it is being installed because of damage to property after hours, improved lighting might be better.
There are four main categories of usage: monitoring flows of traffic or people where individual identities are not required; detecting the presence of people without needing to identify them; recognising individuals; and identifying individuals using high-quality facial images which would be acceptable in court.
The rationale for using CCTV will influence where cameras are sited as they should only capture images in accordance with their defined purpose.
This means that periodic checks should be made to ensure that the cameras have not moved or that the areas covered have not changed; for example, due to the loss of leaves from surrounding trees.
Chapter 10 of the code provides a detailed list of requirements that need to be complied with and appendix two provides a checklist for small organisations such as practices.
Audio recording is subject to strict limitations and most practice CCTV systems will be visual only. It is important that the visual quality meets both the practice's needs and legal requirements.
For example, if the sole purpose is to deter crime during opening hours, cameras capable of identifying individuals may not be needed.
The images that are recorded should be restricted to appropriate and limited access.
For example, cameras in public areas can have monitors which are publicly accessible so that the images shown on the screen capture only what is visible to anyone who is actually in that specific area: for instance, in a reception area.
Images from other areas, such as a corridor, should only be visible to authorised personnel.
Images may be retained for as long as appropriate for the practice's needs. There are no defined time limits.
If the practice uses monitors, you will need to decide where these are located and who is responsible for checking the screens. Receptionists might well be expected to check monitors before authorising access to the surgery after hours.
But, it would usually be regarded as inappropriate for them to monitor the car park to identify suspicious behaviour.
Similarly, if data is recorded out of hours, someone will need to be responsible for checking the recorded footage in the event of any damage or reported incidents.
CCTV should be installed for a specific purpose and be accompanied by advisory signs that clearly state this purpose - for example, for the prevention or detection of crime.
This will enable practices to record identifiable images and to disclose these under certain circumstances. The provisions of both the Data Protection Act and the GMC's patient confidentiality guidelines will need to be met before disclosures are made.
Although patient confidentiality has to be protected, practices can usually disclose details of patients caught on camera in apparently criminal acts.
However, they should only disclose limited and relevant information. For example, if pictures taken in a public area are released, the identities of those not involved need to be blurred or removed before release.
Data security requirements include ensuring that the CCTV system itself is secure to prevent the data collected falling into unauthorised hands.
Signage does not need to display the practice's name if it is obvious from the location that the cameras are managed by the practice.
However, if there is any doubt about this, such as in a shared building or car park, you must include the practice's details and contact information.
- Ms Applebee is a management consultant in primary care and a management partner at a practice in Cornwall www.practiceservices.co.uk
Equipment and costs
CCTV systems come in a wide variety of options. Issues to consider include:
- Complete systems or DIY kits.
- Specialist providers or self-installation.
- Numbers and types of cameras, for example, those suitable for night vision or with self-adjusting lenses, and image resolution.
- Optional monitor screens and where to locate these.
- Recording devices, such as hard drives for digital recording.
Prices vary widely but approximately £100 per camera would provide a system with average capabilities, with additional costs for higher quality cameras, additional monitors, larger storage capability and specialist installation.
Any maintenance and/or contract costs will depend on whether systems are bought separately and installed locally, or provided and maintained by a specialist supplier. These in turn will depend on the size of the practice, its specific needs and the capability of practice maintenance personnel to install ready-made systems. With maintenance contracts, practices should take into account the costs of replacing individual items because this will often be more cost-effective than a contract.
- CCTV Code of Practice 2008, The Information Commissioner, www.ico.gov.uk
- Issue 5 of the Caldicott Guardian newsletter addresses relevant issues, www.connectingforhealth.nhs.uk