How to Comply with GDPR When Using CCTV Systems

Using surveillance systems—from CCTV to smart doorbells or cameras—brings legal obligations under the UK GDPR and Data Protection Act 2018. The ICO emphasizes that such systems must operate lawfully, transparently, and in a way that protects individual privacy.

1. Accountability & Planning

Adopt data protection by design and default: Privacy considerations must be embedded from the earliest stages—choosing systems and deployments that align with legal and ethical standards.
Conduct a Data Protection Impact Assessment (DPIA): Required for any surveillance likely to pose high risks—such as widespread public monitoring or workplace surveillance. If risks remain high after mitigation, you must consult the ICO before proceeding.
Keep detailed records: Document surveillance purposes, retention policies, data sharing arrangements, and more, as required under Article 30 of UK GDPR.

2. Transparency & Fair Use

Make surveillance visible and clear: Use strategically placed signage to inform individuals they are being recorded and how they can exercise their rights.
Respect reasonable expectations of privacy: Avoid surveillance in sensitive zones like changing rooms or private spaces unless absolutely necessary and justifiable.
Assess emerging technologies carefully: Innovations like smart doorbells or facial recognition may alter expectations and raise new privacy considerations.

3. Data Security & Retention

Only keep footage as long as needed: Define the minimal retention period, document it, and securely delete data when it’s no longer necessary.
Secure your systems: Implement safeguards like encryption, controlled access, and secure storage or cloud solutions.
Protect access and workflows: Limit live feed and footage access to authorized staff, maintain procedural checks, update security regularly, and review systems periodically.

4. Upholding Individuals’ Rights & Governance

Be prepared for subject access requests (SARs): Your system should allow easy extraction of footage for legal requests. Staff must know how to handle SARs, erasure, or restriction requests.
Control disclosures: Footage sharing must align with the original purpose and be securely transferred. Any recipient becomes a data controller under UK GDPR.
Use redaction tools when necessary: Blur or mask third parties in footage when fulfilling requests or sharing data.

Conclusion

Adhering to data protection principles in surveillance isn’t just about ticking a compliance checklist—it’s about fostering trust, upholding privacy, and ensuring systems serve their intended purpose ethically. By embedding transparency, accountability, security, and respect for individuals' rights into every stage of your surveillance strategy, you can deploy such systems with integrity and confidence.

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