Installing a CCTV at every workplace is both a necessity as well as proportionate. Throughout Cork, the CCTV cameras are used solely for the stated purposes, unless it is made clear at the very outset that every gathering collected as the CCTV data will be used for justified purposes like offense investigation or to prosecute the offenders or to spot the breaches in disciplinary procedures.The extended CCTV systems usage has its own society-wide implications. As stated by law, the CCTV cameras have to be used with utmost care and considerations so as to avoid the arising concerns regarding the individual’s privacy being eroded for no reason.
The recognizable images the CCTV system cameras capture are personal data and are thus subject to the Data Protection Acts provisions.
Now, the very notion for the employers to install the CCTV cameras at their workplaces in Cork guided by the CCTV policy for the protection of the staff, suppliers, customers, the very premises, and the company property. The protection is to ensure the stakeholders’ health and safety and to make sure everyone is adhering to the company policies strictly.
The cameras placed for recording the external areas ought to be properly positioned that it prevents recording other persons’ private properties.
The Key Considerations for the Employers
The employees are must to follow the data protection procedures and policies which comprise of:
- Clearly stating the very purpose of the CCTV cameras installation and the lawful basis in accordance with the GDPR’s Article 6.
- Informing and communicating with all the employees and even the other data subjects regarding the use of the CCTV footage. Employers must ensure the employees are having access to the company’s data protection policies and re-circulate the policies with amendments. Additionally, added to the included information in the data protection policy as well as the privacy statement, the employers even have the responsibility to ensure displaying apt signage indicating the CCTV footage’s purpose.
- Keeping the policies consistently linked to each other, for instance, the disciplinary policy and the data protection policy must contain an individual reference to the other for the cases where the CCTV footages are to be used in the disciplinary matters.
- Using the CCTV system for monitoring the employees constantly is highly intrusive and needs justification by reference to specific circumstances. If the reasons for monitoring is for health and safety, then the employer must demonstrate the CCTV had been installed was proportionate to address the health and safety issues that came up before the CCTV system was installed.
As stated by the Data Commissioner, a balance should be struck in between an employee’s privacy consideration and the organization’s legitimate interests at the time of using the CCTV cameras in the workplace. The CCTVs are for legitimate use according to the Data Protection Acts for security purposes in various situations. If they are to be used beyond the circumstances, then they have to be fully justified and even evidence-based accompanied by a high threshold for the evidence.
Using CCTV Cameras in the Disciplinary Matters
Putting the CCTV cameras to use in disciplinary matters is not permitted except for the exceptional and special situations justifying the surveillance. In advance, every employee must be notified regarding the installed cameras and the images could be put to use in the disciplinary proceedings.
Using the CCTV cameras should be necessarily proportionate and justified. An employer, normally, justifies the CCTV camera on grounds of security reasons and for preventing loss or theft of stock and the like.
Definitely, the employees have their privacy rights when they are present at their workstation, and CCTV monitoring should be conducted with regards to the transparent and proportionate data protection principles. Hence, the employees should keep all the employees alerted to the CCTV usage along with the monitoring purpose, as the special circumstances should prevail if the employer has to monitor the staff’s attendance and conduct.