- Using CCTV cameras in a healthcare setting, including dental practices, can be problematic because of the need to protect patient confidentiality.
- You also need to consider the relationship of trust between patients and the dental team.
If you want to install cameras in the public areas of your practice to help prevent or detect crime, you need to be confident that CCTV is necessary and proportionate. If you decide to go ahead, record your reasons and regularly review this decision.
CCTV images of patients are considered personal data, which means you must abide by data protection law and follow the relevant national guidance.
If practices are using CCTV equipment, it is essential they have governance arrangements in place that satisfy the Data Protection Act 2018.
Practices should follow good practice described in 'In the picture: A data protection code for surveillance cameras and personal information' (Information Commissioner's Office).
Types of recording
This is done with obvious cameras. Public areas that could be under surveillance include the waiting room, reception area or car park. Cameras should not record personal areas such as toilets.
Private areas would be the dental treatment room. Equipment should not be used to record private conversations in the dental treatment room.
It must be clear to patients when they enter a public area under surveillance that recording is taking place. Signs must:
- be clear and prominent
- explain the purpose of recording
- include the name and contact details of those operating the surveillance scheme.
This is where recording is done without the explicit knowledge of the subjects. This would not normally be undertaken in a dental practice.
Code of practice
The ICO's CCTV Code of Practice contains detailed information on what CCTV operators must do to comply with data protection laws. This includes:
- making sure surveillance technologies are only installed for a specific purpose, such as crime prevention, and that its use is 'justified, necessary and proportionate'
- prominently displaying signs clearly warning visitors and staff that surveillance equipment has been installed
- storing recorded images securely, and retaining them only for as long as is strictly necessary.
The UK government's Surveillance Camera Code of Practice also provides 12 principles for ensuring transparency and appropriate safeguards are kept in place.
This applies to local authorities and the police in England and Wales, but other users (such as those in Scotland and Northern Ireland) are encouraged to adopt the guidance on a voluntary basis.
To meet the GDC's ethical standards, personal information (including images) can only be disclosed without consent to protect patients or the public "in exceptional circumstances".
This includes "if a patient puts their own safety or that of others at serious risk, or if information about a patient could be important in preventing or detecting a serious crime".
- If obtaining consent to disclose CCTV images is not practical or appropriate, the GDC advises you get advice before releasing it.
In general, you are unlikely to be criticised for disclosing footage of a patient committing a crime to the police, but you shouldn't need to provide details of their clinical history or why they attended the practice. Images of anyone unrelated to the incident should be blurred out.
To make sure the CCTV cameras fulfil your intended purpose, seek professional advice about the most appropriate surveillance technology, the location of cameras, facial recognition, time/date stamps, etc. Include guarantees about data security and patient confidentiality.
The practice's data controller should produce a CCTV policy that covers the installation of cameras, the safe storage of images, retention periods and disclosure.
- If you have any concerns about a request to release CCTV images, remember you can always call the DDU for advice.
This page was correct at publication on 20/08/2021. Any guidance is intended as general guidance for members only. If you are a member and need specific advice relating to your own circumstances, please contact one of our advisers.