Closed-Circuit Television (CCTV) Privacy Notice

Welsh Ambulance Services University NHS Trust operates overt closed-circuit television (CCTV) in and around Trust’s sites and on our vehicles. The Trust is the data controller for the personal information captured through its CCTV systems.

This privacy notice explains how and why the Trust collects, uses, stores and shares personal information captured by CCTV.

Who this notice applies to

This notice applies to anyone who may be captured by Trust CCTV, including:

  • patients and service users;
  • Trust staff, volunteers, students and contractors;
  • Passengers, visitors;
  • pedestrians and members of the public;
  • road users; and
  • individuals present at or near Trust premises and vehicles.

What information we collect

Depending on the system, camera location and circumstances, CCTV may capture:

  • video images of identifiable individuals;
  • the date, time and location of an incident;
  • images of vehicles, property and the surrounding environment;
  • movements and activity around Trust vehicles;
  • information relating to accidents, incidents or potentially unlawful activity;
  • information about users who access CCTV systems, including their name, email address, role and audit activity.

Although CCTV is not ordinarily intended to collect special category personal data, images may reveal information about an individual’s health, disability, racial or ethnic origin or religious beliefs. Vehicle CCTV may also incidentally capture a patient receiving assessment or treatment. Audio recording is not enabled.

Vehicle CCTV

Cameras are positioned around the exterior of the vehicle, together with a camera in the patient saloon. External cameras record during vehicle operation. The internal saloon camera is configured to record when activated through the vehicle’s panic strip.

Please note: the surveillance cameras inside our vehicles are only activated by the crew should they feel there is a risk to safety. Should the CCTV be activated, you will be advised by the crew (and/or an audio message will be played for CCTV whilst inside the vehicle).

Site CCTV

CCTV cameras are located across Trust premises and ambulance stations. Some CCTV monitors may be available to authorised staff for safety-monitoring purposes.

Some Trust premises are shared with other emergency services. Police or Fire and Rescue Service personnel may therefore have access to CCTV at certain shared locations, depending on the ownership and operation of the system. Signs will be displayed where CCTV is in operation, including details of the organisation responsible for the CCTV.

Why we use CCTV

The Trust may use CCTV where this is necessary and proportionate for the following purposes:

  • Protection of Trust Assets: To safeguard Trust premises, vehicles, buildings, equipment, and other assets from damage, theft, unauthorised access, or other criminal activity.
  • Enhancing Safety and Security: To promote the personal safety of staff, patients, and visitors, reducing the fear of crime and serious harm.
  • Crime Prevention and Investigation: To support law enforcement bodies and Accredited Counter Fraud Specialists in the prevention, detection, and prosecution of crime, including but not limited to fraud, violence, and theft.
  • Incident Investigation: To assist in the investigation of criminal activity, road traffic collisions involving Trust vehicles, and serious harm.
  • Protection of Individuals and Property: To protect members of the public, service users, and private property within the Trust’s operational scope.
  • Operational Oversight: Supporting the effective management of Trust sites, vehicles and incidents.
  • Deterrence of Criminal Activity: Supporting Police and external agencies to deter and detect criminal behaviour, including fraud and violence.
  • Workplace Protection: Safeguarding employees and service users from acts of violence, aggression, abuse or serious harm in the workplace.
  • Legal Proceedings: Where it is necessary to establish, exercise or defend legal claims.

CCTV footage is accessed only where there is an authorised, necessary and proportionate reason connected to one of the defined purposes.

Lawful basis

The Trust relies on Article 6(1)(e) of the UK General Data Protection Regulation, as the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Trust. This includes the provision and effective management of ambulance services, the protection of public safety and the investigation of serious incidents.

Where footage incidentally captures special category personal data, the Trust relies on Article 9(2)(g) of the UK GDPR, as processing may be necessary for reasons of substantial public interest. Depending on the circumstances, the relevant conditions in Schedule 1, Part 2 of the Data Protection Act 2018 may include:

  • preventing or detecting unlawful acts;
  • protecting the public against dishonesty, malpractice or other seriously improper conduct; and
  • safeguarding children and individuals at risk of harm.

The condition relied upon will be considered in the context of the specific access, use or disclosure of the footage.

How footage is stored and protected

CCTV footage is held electronically. Depending on the system, footage may be stored:

  • on secure hard drives within the UK;
  • within a UK-hosted cloud environment; or
  • within an access-controlled Trust network location after authorised extraction.

Access is restricted to authorised personnel with a legitimate need to carry out their role. Controls include individual user accounts, role-based access permissions, physical security, secure storage and audit logging.

Who may have access to the footage

Access may be provided on a need-to-know basis to authorised staff. Upon receiving an official request to provide surveillance camera evidence, the Records Team and/or the Legal Services Team would facilitate access to the relevant files and download the requested footage. This would then be passed to relevant parties who have a legitimate reason to review it.

Suppliers may provide hosting, maintenance or technical support. Vue Ltd acts as a data processor in relation to the primary Fleet CCTV system. Supplier access to footage is not permitted unless expressly authorised by the Trust for a defined purpose, such as retrieving footage that the Trust is unable to access directly.

When information may be shared

Where it is lawful, necessary and proportionate, relevant footage may be shared with:

  • the police and other law-enforcement bodies;
  • courts and tribunals;
  • insurers and legal representatives;
  • regulatory, investigatory or statutory bodies;
  • Accredited Counter Fraud Specialists;
  • individuals exercising their data protection rights; or
  • another recipient where disclosure is required or permitted by law.

All requests are considered individually. The Trust will assess the purpose, lawful basis, necessity and proportionality of a proposed disclosure before releasing footage. Disclosures must be authorised, documented and made through an appropriately secure method.

Where footage contains information about other people, the Trust may need to redact, obscure or withhold parts of the footage to protect their rights and confidentiality.

How long we keep the footage

Routine vehicle-based CCTV footage is normally retained for no longer than 28 days, after which it is automatically overwritten on a rolling basis.

Relevant footage may be extracted and retained for longer where this is necessary, including for investigations, legal proceedings, or another authorised purpose permitted by law.

Footage shared for law-enforcement purposes may be retained for up to 3 years. Footage required for an internal investigation, litigation or legal proceedings may be retained for the duration of the matter and, following conclusion, for a further period of 10 years.

Your data protection rights

Depending on the circumstances, you may have the right to:

  • request access to CCTV footage containing your personal data;
  • request correction of inaccurate associated information;
  • object to the processing of your personal data;
  • request restriction of processing;
  • request erasure of your personal data; and
  • raise a concern about the way your information has been handled.

These rights are not absolute. For example, the Trust may need to retain or withhold footage where this is necessary for public safety, the prevention or detection of crime, legal proceedings, safeguarding, the rights of other people or another overriding legal obligation. Requests will be considered individually under applicable data protection legislation.

Requesting access to footage

You can ask whether the Trust holds CCTV footage containing your image and request a copy by submitting a subject access request.

To help us locate relevant footage, you should provide as much information as possible, including:

  • the date and approximate time of the incident;
  • the location;
  • the vehicle registration, call sign or other vehicle details, if known;
  • a description of the circumstances; and
  • information that will help us identify you within the footage.

Requests for CCTV footage are managed by the Trust’s Records Services and Archives Team under the Trust’s Subject Access Request Procedure. The Trust will request evidence of identity and may need to obscure images of other identifiable people before footage can be released.

Requests can be submitted by visiting:  Requests for Records - Welsh Ambulance Services University NHS Trust.

Concerns and complaints

If you have a concern about CCTV or how the Trust has handled your personal information, please contact:

Data Protection Officer
Welsh Ambulance Services University NHS Trust
Email: amb_infogovernance@wales.nhs.uk
Address: Tŷ Elwy, Richard Davies Road, St Asaph, Denbighshire, LL17 0LJ

You also have the right to complain to the Information Commissioner’s Office if you are dissatisfied with the Trust’s response. Information about raising a complaint is available from the Information Commissioner’s Office.