Effective from: 1 April 2026
1. Introduction
This policy sets out Cheshire West Recycling’s (CWR) corporate position on the use of surveillance camera systems and body-worn video across all areas of its operations.
CWR uses surveillance systems to support safety, security, service delivery and lawful business operations. These systems are deployed in a range of environments including vehicle fleets, depots, Household Waste Recycling Centres (HWRCs) and other public-facing operational settings.
This policy establishes the principles, governance and boundaries for surveillance at CWR. Detailed operational rules, procedures and guidance are provided separately and must be read in conjunction with this policy.
2. Statement of Intent
CWR is committed to using surveillance systems lawfully, fairly and proportionately.
Surveillance will only be used where it is necessary for a legitimate business purpose, and in a manner that respects the rights, dignity and privacy of employees, contractors, visitors and members of the public.
CWR will not use surveillance systems in a way that is excessive, disproportionate or unfair.
3. Legal and Regulatory Framework
This policy is informed by, and will be applied in accordance with, the following legislation and guidance:
- UK General Data Protection Regulation (UK GDPR)
- Data Protection Act 2018
- Human Rights Act 1998
- Investigatory Powers Act 2016
- Information Commissioner’s Office (ICO) Surveillance Camera Code of Practice
- Protection of Freedoms Act 2012
- Any other relevant statutory or regulatory requirements
4. Scope of the Policy
This policy applies to:
- All CWR employees, agency staff, contractors and volunteers.
- Members of the public interacting with CWR services.
- All surveillance systems operated, managed or controlled by CWR, including:
- Fixed CCTV systems at depots and operational sites
- CCTV systems at Household Waste Recycling Centres (HWRCs)
- Vehicle-mounted cameras and telematics systems
- Body-worn video (BWV) cameras
- Any future surveillance technology of a similar nature
Where CWR operates surveillance systems on behalf of a client, landlord or local authority, the respective roles and responsibilities of the parties will be clearly defined.
Where CWR acts as Data Controller, this policy will apply in full.
Where CWR acts as Data Processor on behalf of another organisation, CWR will comply with the documented instructions of the Data Controller and the relevant contractual or statutory requirements. In such cases, this policy will apply to the extent that it is consistent with those requirements.
5. Principles Governing the Use of Surveillance
All surveillance activities undertaken by CWR will be governed by the following principles:
- Surveillance will be lawful and have a clear legal basis.
- Surveillance will be necessary and proportionate to the risk being addressed.
- Surveillance will be transparent, with clear signage, communication and information on where to find the Privacy Notice.
- Surveillance will be limited to defined and legitimate purposes.
- Systems will be designed and operated to minimise intrusion into private life.
- Surveillance will not be used for routine, continuous or speculative monitoring of employee performance.
- Audio recording will not be used unless clearly justified, authorised and supported by a specific Data Protection Impact Assessment.
6. Purposes for Which Surveillance May Be Used
Surveillance systems may be used for the following legitimate purposes:
- Protecting the health, safety and wellbeing of employees and members of the public.
- Preventing, detecting and investigating crime, disorder or antisocial behaviour.
- Investigating accidents, incidents, near-misses and dangerous occurrences.
- Supporting the resolution of complaints, claims, disputes and allegations.
- Protecting CWR assets, vehicles, plant and property.
- Managing operational and safety risks in public-facing environments, including HWRCs.
- Supporting staff in managing challenging or aggressive situations.
- Monitoring compliance with site rules, traffic management arrangements and charging regimes at HWRCs where necessary to support safety, security and effective site management.
Surveillance will not be used for purposes outside those set out above.
7. Operation of Surveillance Systems
CWR operates a range of surveillance systems, including fixed CCTV, vehicle-mounted cameras, surveillance at HWRCs and body-worn video.
All systems will be:
- Installed in visible locations.
- Operated in accordance with this policy and supporting procedures.
- Configured to avoid unnecessary intrusion into private areas such as welfare facilities and changing, rest and kitchen areas.
Body-worn video is recognised as more intrusive than fixed CCTV and will be subject to additional controls set out in separate guidance.
8. Monitoring and Review of Footage
Live monitoring and retrospective review of footage will only take place where justified for the purposes set out in this policy. Access to footage is restricted to authorised personnel only.
Surveillance footage will not be routinely monitored for performance management purposes. Where footage is used in disciplinary or investigatory processes, this will be handled fairly and in accordance with CWR policies and procedures.
9. Access to Data
Access to surveillance footage and associated data is strictly controlled. Only authorised personnel with role-based access who have received appropriate training may access or handle recorded material.
All access will be logged and auditable.
10. Retention of Footage
Recorded footage will be retained for defined periods in line with CWR’s retention schedules. Footage will be retained for no longer than necessary and will be securely deleted once the retention period expires, unless it is required for an ongoing investigation, claim or legal process.
11. Disclosure and Subject Access Requests
CWR recognises the rights of individuals under data protection legislation. In relation to surveillance systems, these include:
- Right to be informed – Supported through clear signage, privacy notices and transparency measures.
- Right of access (Subject Access Requests) – Individuals may request access to footage containing their personal data; requests will be handled in accordance with data protection legislation and CWR policies.
- Right to restriction of processing – Requests will be considered on a case-by-case basis, taking into account the lawful basis and purpose of the surveillance.
- Right to object – Where processing is based on Legitimate Interests, objections will be assessed against CWR’s lawful basis and operational requirements.
- Right to rectification – Unlikely to apply to recorded footage, but any request will be considered in line with legal requirements.
- Right to data portability – Not normally applicable to CCTV or body-worn video footage.
- Rights in relation to automated decision-making – Not applicable, as CWR does not use surveillance systems for automated decision-making.
All external requests for disclosure of surveillance footage will be referred to the Data Oversight Group (DOG) in the first instance, with the involvement of the DPO as required.
12. Data Protection Impact Assessments and Legitimate Interest Assessments
Data Protection Impact Assessments (DPIAs) will be completed and reviewed as required:
- Prior to the introduction of new surveillance systems.
- Where existing systems are significantly changed.
- For the deployment or expansion of body-worn video.
Where Legitimate Interest is relied upon as the lawful basis for processing, Legitimate Interest Assessments (LIAs) will be completed.
13. Training and Awareness
All staff will receive appropriate training and information regarding the use of surveillance systems. Staff authorised to operate or access surveillance systems will receive enhanced training, including data protection and privacy awareness.
14. Breaches, Complaints and Concerns
Any suspected misuse of surveillance systems, data breaches or complaints will be investigated promptly and in accordance with CWR procedures. Serious breaches may result in disciplinary action.
15. Review of the Policy
This policy will be reviewed annually, or sooner where there are significant changes to legislation, technology, operational practices or risk profile.