CCTV, Audio and Body-Worn Camera Policy

Last updated: 27 September 2026

1. Introduction

ASL Vets Ltd is committed to the safety and security of our clients, patients, staff and premises. This policy explains how and why we use closed-circuit television (CCTV), audio recording (including telephone call recording), and body-worn cameras, at our practices.

This policy applies to all staff, clients, contractors and visitors at ASL Vets Billericay and ASL Vets Wickford.

2. Purpose and scope

We use CCTV, audio recording, telephone call recording and body-worn cameras to:

• protect the safety and security of clients, patients, staff and visitors;
• prevent and investigate theft, vandalism or other criminal activity;
• monitor and improve the quality of the services we provide;
• protect company property and assets; and
• assist in resolving disputes or complaints.

3. Legal basis

We process CCTV, audio and body-worn camera data under:

• the UK GDPR and Data Protection Act 2018;
• ICO guidance on video surveillance and the ICO’s guidance on monitoring workers; and
• our legitimate interests (Article 6(1)(f) UK GDPR), balanced against the rights and freedoms of clients, staff and visitors, as assessed in our Data Protection Impact Assessment.
• the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000, in relation to the recording of telephone calls.

CCTV, audio and body-worn camera recording is carried out at our premises on this legitimate-interests basis. We do not rely on, and do not need, your consent for recording to take place — but we are committed to being transparent about it, which is why this policy and clear signage are in place.

4. Recording coverage

Audio and video recording is active on fixed cameras covering reception, consulting rooms, the preparation area and the surgical theatre. No recording takes place in private or sensitive areas, such as staff restrooms or changing facilities.

Telephone calls, both inbound and outbound, are recorded for training, monitoring and quality assurance purposes. Callers are notified at the start of the call and may decline; if they do, we will offer to deal with the matter by email instead.

To comply with PCI DSS payment card security rules, call recording is paused whenever payment card information is being taken, and resumes once the transaction is complete.

5. Body-worn cameras

In addition to our fixed CCTV and audio systems, staff in front-of-house and clinical roles may be issued a body-worn camera (BWC) for personal safety.

• Purpose: to protect staff from verbal or physical aggression and to deter such behaviour, and to provide reliable evidence in the event of an incident, complaint or dispute — including to help correct false or misleading public allegations made against the practice or its staff.
• Event-triggered, not continuous: body-worn cameras are not used for routine or continuous monitoring of staff performance or conduct. They are activated by the wearer only in response to a defined safety trigger (for example, aggressive, intimidating or threatening behaviour), as set out in our internal Safe System of Work.
• Device and safeguards: our body-worn cameras (Brifield BR1 NEO) record a 30-second buffer immediately before and after activation, and are protected by a passcode held only by the Practice Manager — the wearer cannot view, copy or delete footage from the device. Footage is transferred to our secure practice system by the Practice Manager only.
• Legal basis and assessment: the same legitimate-interests basis as our fixed CCTV and audio recording (section 3), supported by a Data Protection Impact Assessment that specifically addresses the risks of body-worn camera use.
• Retention and access: footage is retained for 30 days and access is restricted on the same basis as fixed CCTV footage (section 9).
• Release outside the practice: footage is only shared outside the practice — for example with the police, our insurer, our legal advisers, or to correct a specific false public allegation — where our defined release criteria are met, only the minimum necessary footage is used, uninvolved third parties are blurred, and the release is documented and authorised.
• Training: staff issued a body-worn camera complete training before first use and follow our internal Safe System of Work.

6. Why we record audio, not just video

Continuous audio recording is more intrusive than video alone, and we have specifically considered whether it is necessary and proportionate:

• Alternatives considered: video-only recording; recording that activates only when triggered (for example, by a panic button or duress alarm); and audio recording limited to reception only.
• Why audio was retained in consulting rooms and theatre: to protect staff during clinical procedures involving risk of injury (from distressed or aggressive animals or owners), to support accurate incident investigation where video alone cannot show what was said, and to support staff training and clinical governance.
• Mitigations: recording is limited to clinical and client-facing areas only (never private staff spaces); access to footage is restricted (see section 10); retention is short (30 days); and clients and staff are clearly informed via signage and this policy.

We recognise that clients sometimes disclose sensitive personal information about themselves (for example, their own health or financial circumstances) during a consultation, which could incidentally be captured on the audio feed. We treat this as a data protection risk in its own right — it is addressed in our Data Protection Impact Assessment, and access to recordings is restricted accordingly (section 10).

7. Staff monitoring

Continuous recording of consulting rooms and the theatre necessarily involves monitoring our own staff while they work. In line with the ICO’s guidance on monitoring workers, we have considered this separately from client/visitor monitoring:

• CCTV and audio recording has been in place at ASL Vets since the company was established, and has always been referenced in the Staff Handbook and related company policies — this is not a new form of monitoring;
• this standalone CCTV, Audio and Body-Worn Camera Policy was refreshed, and staff were briefed on the updated terms — including the retention periods and named access roles set out below — on 1 November 2026;
• recording is continuous rather than covert or targeted at individuals, and is not used for routine performance management — it is accessed only for the purposes in section 2;
• body-worn cameras are treated differently from this continuous monitoring: they are activated only in response to a defined safety trigger, and are never used to monitor staff performance or conduct (see section 5);
• staff can raise concerns about the policy with their line manager or the Practice Manager at any time.

8. Transparency and signage

• Prominent signage informs all visitors and staff that audio and video recording is in use, at both practices.
• Where a member of staff is wearing a body-worn camera, this is in addition to — not instead of — the fixed CCTV and audio signage already in place.
• Staff are trained to explain our recording practices clearly and respectfully if asked.

9. Data retention and access

• CCTV footage and body-worn camera footage are each retained for 30 days. Telephone call recordings are retained for 90 days, reflecting the time typically needed to review and resolve client complaints, staff training matters and payment disputes arising from telephone interactions. In each case, where footage or a recording is needed for an ongoing investigation, legal proceedings, or other legitimate purpose, it is retained only for as long as that purpose requires.
• Fixed CCTV recording operates on a continuous basis, 24 hours a day, 7 days a week. Body-worn cameras are event-triggered only (see section 5).
• Access is strictly limited to Directors, Senior Managers and the Practice Manager, and only for the purposes set out in section 2.
• After the applicable retention period (30 days for CCTV and body-worn camera footage; 90 days for telephone call recordings), data is automatically and securely erased.

10. Security measures

• Systems are password-protected and encrypted.
• Body-worn camera footage is additionally passcode-protected on the device itself, and can only be transferred to our secure system by the Practice Manager.
• Access logs and audit trails are maintained.
• Access and retention settings are reviewed regularly to check for misuse or drift from this policy.

11. Your rights

If you appear in our CCTV, audio or body-worn camera recordings, you may:

• request access to footage or audio involving you;
• object to our processing, where applicable; and
• request erasure, subject to our legal and legitimate business requirements.

Requests should be made in writing to the Practice Manager at ASL Vets Ltd, 5 The Pantiles, Billericay, Essex, CM12 0UA, or by email to info@aslvets.co.uk. We will respond within one month. You may also complain to the Information Commissioner’s Office (ico.org.uk).

12. Governance and review

• A Data Protection Impact Assessment is maintained for our CCTV, audio and body-worn camera recording, and is reviewed alongside this policy.
• An internal Safe System of Work governs the day-to-day use of body-worn cameras and is reviewed on the same basis.
• This policy is reviewed annually, or sooner if the law, our systems, or our premises change materially (including when a new site opens or new recording equipment is introduced).
• Breaches are reported in line with our data breach procedure.

13. Complaints and queries

Any complaints or queries about our use of CCTV, audio recording or body-worn cameras should be directed to the Practice Manager. We will investigate promptly and take appropriate action.