Portree Dental Practice
Policy Latest Updated: 04/06/2025
Original Policy Date: 20/07/2022
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.
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.
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.
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
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"
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
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)
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).
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.
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
Mr Zahid Ahmad
Responsible person for the premises lease holder under company & Principal Dentist
Portree Dental Practice
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.
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