DPIA and Student Toilet CCTV

[Gongalong]

Hi folks,

 

We are looking at putting CCTV in our student toilets. We are aware of and have read the ICO article on the subject of CCTV, which covers toilets, need for a DPIA etc.

 

Are there any other DPOs out there in schools that have already done this that are OK with sharing their DPIA, and any other lessons learned?

 

Feel free to contact me via PM.

 

Thanks

[6Foot2]

Three things I made sure were in place when we put CCTV into student toilets:

 

1. Wherever possible, the cameras should not record areas where personal privacy could be a concern (difficult to cover areas of potential concern without invading individual privacy)
   
2. Put digital blocks in place where, without those blocks, privacy may have been compromised (e.g.: Where mirrors could have cause images to be captured that should not have been: See point 1)
   
3. Whenever I was responding to a request for CCTV data, I made sure that a "chaperone" was present monitoring/witnessing my actions but also, sometimes, assisting with the investigation.
   

I suppose this might seem overcautious, to some, but I wanted to minimize the chances of a complaint arising from our cue of CCTV in toilets, or elsewhere.

Edited September 9, 2023 by 6Foot2
Added a missing word for more sense. :(

[GrumbleDook]

Three things I made sure were in place when we put CCTV into student toilets:

 

1. Wherever possible, the cameras should not record areas where personal privacy could be a concern (difficult to cover areas of potential concern without invading individual privacy)
   
2. Put digital blocks in place where, without those blocks, privacy may have been compromised (e.g.: Where mirrors could have cause images to be captured that should not have been: See point 1)
   
3. Whenever I was responding to a request for CCTV data, I made sure that a "chaperone" was present monitoring/witnessing my actions but also, sometimes, assisting with the investigation.
   

I suppose this might seem overcautious, to some, but I wanted to minimize the chances of a complaint arising from our cue of CCTV in toilets, or elsewhere.

*Really* good points and are definitely things I would mention too.

I can add a few more that may be helpful.

 

All requests are logged (including the purpose for review), but where a significant privacy concern is raised consider if the authorisation for looking at footage needs to be different (and get this decision down in your DPIA and risk register)

Consider any impact on the mental health of those being asked to review footage where there may be a privacy concern.