People who use your service or their families may raise concerns about privacy. If they do, you must take steps to address them. Aim to make the impact on people's privacy as small as possible.
If you use surveillance, you must do this in a way that treats people with dignity and respect.
Ways to lessen the impact on people's privacy
There are some kinds of protection that are relevant to all surveillance. For example, you must make sure only the right people have access to the information you collect.
Other steps you can take depend on particular situations or risks you've identified. These are things like:
- changing the position of cameras or microphones, or only using them at certain times – this might help you avoid capturing more private things, like intimate care
- finding ways to gather information that does not identify people – like statistical information from sensors rather than video
- allowing staff or people that use the service to turn off equipment at certain times
- following the ICO's guidance on video surveillance (including guidance for organisations using CCTV) and the Biometrics and Surveillance Camera Commissioner's Amended Surveillance Camera Code of Practice, which cover the positioning and use of CCTV cameras.
When to take extra care
- Avoid recording sensitive things like intimate care or people privately observing religious beliefs.
- If staff wear body cameras, it’s important to switch them off when they’re giving intimate care.
The more surveillance threatens people’s privacy, the stronger the justification for using it must be.
You must keep a record of how you have looked at privacy concerns and any that you have not been able to address.