Most Licensed Premises are required to have, and maintain in full working order, a CCTV system. Occasionally some premises are effectively excused – like a small restaurant where very few and only problems are anticipated by the Responsible Authorities – but by and large, the provision of CCTV has become a standard requirement.
✍️ Look at your own Premises Licence – most specifically Part A. The requirement to have CCTV is usually the very first condition under the ‘Prevention of Crime & Disorder’ Licensing Objective. If it is there, it will most likely look something like this standard wording:
1.1 The premises shall install and maintain a CCTV system as per the minimum requirements of the Police licensing department, current Home Office guidelines and in line with the Information Commissioner’s Office current CCTV Code of Practice. The CCTV system shall have sufficient storage capacity to store a minimum of 31 days footage and record images at 7-12 frames per second. (Advisory note: – The CCTV system must be registered with Information Commissioners Office to ensure compliance with the Data Protection Act 1998).
1.2 Cameras shall be installed and located at the following locations; main entrance/exit, external drinking/smoking area, bar serving areas, circulation areas, seating area and toilet access points to enable the capture of images of individuals to a minimum of “RECOGNISING” as defined in the Information Commissioners Office current “CCTV code of practice”. The CCTV system shall be capable of obtaining clear facial recognition images and a clear head and shoulders image of every person entering or leaving the premises at each exit and entrance point.
1.3 All elements of the CCTV System must be maintained in good working order and recordings date and time stamped.
1.4 Staff shall be trained in the effective and timely operation of the CCTV system to ensure rapid data retrieval & downloads of footage can be provided to the Police & the Local Authority Officer upon reasonable request in accordance with the Data Protection Act.
1.5 CCTV shall be active during licensed hours and at least one member of staff who is trained in downloading from the system must be on the premises during trading hours.
1.6 In the event of a failure of the CCTV system for any reason, a record of the failure will be recorded in the premises’ incident book and immediate steps will be made to rectify the problem.
1.7 CCTV recordings shall be made available, in downloadable and operable format, to the Police or an authorised officer (as defined by s 13 of the Licensing Act 2003 upon reasonable request, and/or in any event within 24 hrs of any request made by the above-mentioned officer(s).
The above conditions are technically complicated, highly specific and quite exacting. You will therefore need to pay particular attention to them OR engage a reputable CCTV company who are highly experienced and professionally competent in installing systems to these standards. This will also give you added comfort in that, if they do it for you, you have someone to call out when it goes down and/or someone to sue if it all goes wrong!
What is immediate evident from this condition is this:
✍️ You will need to register your own system with the ICO at: https://ico.org.uk
✍️ You will need to learn how to operate your own system, and then will have to train your staff in how to operate the system for when you are not there – and then further retrain them regularly so that they remember how to operate the system.
✍️ Your system will have to be password protected, preferably with individual passwords for each member of staff so that you can ascertain who has looked at what, when and why.
✍️ You will need to create an easy to follow sheet of basic instructions on how to use the system, that you should then laminate, and keep safe so that unauthorised people may not access your system when you are not there.
✍️ You will need a small stock of blank data sticks or recordable media– so that you can download footage for the Police, should they ask ever for it.
Overarching CCTV Guidelines
- Know why you want CCTV and which specific areas it will monitor.
- Tell your neighbours and staff that you are installing CCTV.
- Put at least one Data Controller notice up, warning there is CCTV on the property, with a contact phone number.
- Position your CCTV cameras for minimal intrusion, e.g. avoiding any neighbouring properties or public spaces.
- If you can’t help it, consider using ‘privacy masking’. (See page 20)
- Do not record conversations between members of the public.
- Do not install CCTV in traditionally private places, such as toilet cubicles and urinals.
- Don’t keep recordings for longer than you need to. (31 days is recommended standard).
- Older images after 31days should automatically overwrite..
- Do not use CCTV recordings for any purpose other than protecting your property and customers.
- Do not share any CCTV recordings publicly e.g. on social media sites. (See page 20)
- Keep recordings secure and restrict access to them.
- Make sure you understand exactly how your CCTV system works so you’re not caught out.
- Make sure the date & time are set correctly. This should be recorded in your CCTV Logbook
- Make sure you have enough recording space. NB This will vary due to the number of cameras, Live/Motion Recording and the frame rate.
- Check your CCTV system regularly and maintain it (we recommend an annual service).
- Maintain a CCTV Log.
✅ You can download a templated CCTV Log from the TLG Vault for free.
CCTV – Related Matters
Privacy Masking:
‘Privacy Masking’ is technology that ‘blanks’ out sensitive areas on a recording, like a neighbour’s window.
If you operate CCTV in areas where the public have access, you need to register as a CCTV operator with the Information Commissioner’s Office. Get in touch to check at https://ico.org.uk
✅ You can download a CCTV poster from the TLG Vault for free.
Sharing CCTV Footage:
Footage and Stills can be shared under authorised crime intelligence sharing systems (such as DISC) as these systems are registered with the Information Commissioner’s Office and subject of Data Protection regulations.
However, the sharing of CCTV imagery over platforms such as Facebook and What’s App is to be expressly discouraged as these systems are NOT Data Protection compliant.
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