CCTV & Audio Recording Policy

Portree Dental Practice
Policy Latest Updated: 04/06/2025
Original Policy Date: 20/07/2022
 

1. Introduction

Closed-circuit television (CCTV) is used at Portree Dental Practice to protect patients, staff, and the premises. This includes:

• Monitoring high-risk public areas

• Supporting investigation of complaints or confrontational incidents

• Detering and documenting abuse or antisocial behaviour

Our system includes both video and limited audio recording, now active in specific areas, in line with UK GDPR, Data Protection Act 2018, and ICO guidance, all of which apply in Scotland.

2. Location of Cameras

Cameras are positioned in the:

• Reception area (high-risk public area)

• Entrances 

• Lobby and entrance

• Principal Dentist’s office (due to repeated staff confrontations)

Audio recording is active only in:

• Reception area

• Principal Dentist’s office

There is no audio recording in clinical rooms, staff break rooms, toilets, or general office areas.

3. Purpose & Justification for Audio Recording

The decision to enable audio recording in selected areas is based on:

• An increase in confrontational or aggressive behaviour from patients at reception

• Recent staff conflicts in the Principal Dentist’s office

• Need to provide evidence in disputes, complaints, or claims

• Ongoing risk assessments and consultations with staff

The lawful basis under UK GDPR is legitimate interests (Article 6(1)(f)), balanced carefully against individual privacy rights.

4. Recording Method

• Video is recorded 24/7

• Audio is recorded only in designated high-risk areas

• Audio capture is trigger-based (e.g. by motion or voice activation) and not constant

• All recordings are securely encrypted and stored via Tapo cloud-based cameras (Tapo Care)

• All data is stored in line with UK GDPR principles

5. Signage and Transparency

Signage is clearly displayed in:

• Reception area

• Principal Dentist’s office

• Practice entrance

• Website and internal staff platforms

Updated signs explicitly state:
"CCTV and Audio Recording in Use in This Area for Safety and Security"

6. Access, Storage, and Retention

• Access to all recordings is restricted to:

  • Mr Zahid Ahmad (Data Controller)

  •  

• Retention is up to 30 days, unless required for investigation

• Cloud storage (Tapo) is encrypted and secured

• Any playback or access is fully logged and documented

7. Disclosure of Recordings

Access or disclosure will only occur:

• As part of an internal investigation

• In response to police or regulatory requests

• When required for legal defence or incident review

All disclosures follow strict access protocols and are logged with:

• Names

• Purpose

• Dates

• Crime numbers (if applicable)

8. Staff and Visitor Rights

Under UK GDPR, individuals may:

• Request access to recordings that feature them

• Submit a Subject Access Request (SAR) in writing

• Provide sufficient detail to identify date/time/area of concern

A £2000 charge may apply in cases of exceptional workload (e.g. redacting third-party data).

9. Consultation and Review

This policy update follows:

• Staff and management consultation (since February 2023)

• Documented incidents involving staff aggression and patient abuse

• Ongoing risk and compliance reviews

We remain open to feedback. Staff can raise informal concerns with Madiha Naz (HR), or follow the grievance process for formal concerns.

10. Compliance

This policy complies with:

• UK GDPR

• Data Protection Act 2018

• Information Commissioner's Office (ICO) guidance

• The legal framework applicable in Scotland

All use of surveillance is:

• Proportionate

• Transparent

• Limited to legitimate purposes

• Fully compliant with privacy principles

11. Data Controller Contact

Mr Zahid Ahmad
Responsible person for the premises lease holder under company  & Principal Dentist
Portree Dental Practice

12. Version Control and Disclaimer

This version supersedes all prior CCTV policies.
All staff must check internal channels (website, WhatsApp) for updates.

DISCLAIMER: This policy is issued in good faith. The practice accepts no responsibility for omissions and reserves the right to amend it without notice as regulations or operational needs evolve.