FOI release

Use of CCTV cameras in toilets

Published 16 August 2022

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This publication is available at https://www.gov.uk/government/publications/use-of-cctv-cameras-in-toilets/use-of-cctv-cameras-in-toilets

1. Request

I recently completed my CCTV course and I was informed CCTV cameras are not allowed to be used in toilets. Yet on two occasions when I have done events, cameras were in place in male, female, and gender neutral toliets. Could you please clarify the law on this.

2. Response

The SIA holds information that may be of assistance.

The SIA does not regulate the installation or positioning of CCTV cameras but holds information that may be of assistance. There is no specific legislation that references the use of cameras in toilets.

The Information Commissioners Office have produced a blog on what needs to be considered prior to installing CCTV which considers the issue from a privacy and data protection perspective. The Biometrics and Surveillance Camera Commission have produced a Surveillance Camera Code of Practice which operators and users of surveillance cameras are encouraged to adopt voluntarily.

The Knowledge and Skills Specification for Public Space Surveillance published by the SIA is a document which is intended to provide a clear specification on the approach that has been agreed by the SIA and key stakeholders in relation to the core learning and resulting qualifications required by SIA licensing.

Objective 1 of session 2 (‘Legislation’) states that care must be taken that the use of such must be proportionate, limited, specific, adequate, and relevant, in line with regarding Data Protection Act. Objective 6 states that consideration also needs to be given to potential acts of voyeurism.

I have taken an extract from the indicative content below, that goes into this in more detail about this.

2.1 Session 2: Legislation

Aim: To understand the different types of legislation and how they impact on Public Space Surveillance (CCTV) operations.

Objective 1: Identify how the Data Protection Act impacts on to the role of a CCTV Operator.

The meaning of “confidentiality” as it applies to the role of a CCTV operator:

  • compliance with 6 principles of the Data Protection Act
  • not disclosing information to any unauthorised persons relating to all operational aspects of the system and data security
  • no unauthorised recording e.g., using mobile phones or similar devices
  • no unauthorised copying of footage
  • body worn cameras
  • UAVs (drones)

Repercussions of breaches, for example:

  • dismissed, fines and potential prosecution

Objective 6: Identify how the offence of voyeurism impacts on public space surveillance (CCTV) operations

Safeguarding requirements:

  • safeguarding children and young people, and others including voyeurism, limits what you can view and record
  • what considerations to take before viewing CCTV material
  • voyeurism falls under the Sexual Offences Act 2003

[Reference: FOI 0351]

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