Surveillance can intrude on people's privacy. So it's important you discuss it with the people whose privacy it's likely to affect.
Talking to people is the best way to understand their concerns about privacy. You must do this wherever it's practical.
Who you should talk to
People whose privacy surveillance is likely to affect are:
- people who use your service
- their families and friends
- your staff
- trade unions
- visitors to your service.
When to talk to them
Consulting people is not a one-off exercise. It's something you should repeat at different stages while you are considering and using surveillance.
For example, it could be useful to talk to people:
- when you first consider using surveillance – this can help you understand if they welcome it or if they have concerns
- when you've worked out detailed proposals
- from time to time while you're using surveillance – so you can keep reviewing its impact.
What to consult people about
You should tell people:
- why you're considering surveillance (your purpose)
- what type of surveillance you're thinking about using
- where you're considering using it
- what information you will collect
- where and how you'll store the information
- who will have access to the information and how long you'll keep it.
It's best to keep a record of the process you follow when you consult people, along with their responses.
You'll need to consider any privacy concerns they raise. You should look at these as part of your DPIA.
You may need consent
Your initial consultation with people is not the same as getting consent. Find out more about consent.
There are limited circumstances when you can't consult people
In special circumstances, it might not be possible to consult people. For example, you might want to use surveillance for a short time to look into concerns about abuse. If talk to people about it, this could risk alerting people who may be involved.
If you decide not to consult people, it's important you can justify your decision.