Operated by: Nudge Education Ltd · Version: Dec 2025 · Owner: Director of Operations
CCTV Usage and Data Management Policy
December 2025 Review Date: December 2026
Introduction
At Nudge Education, we highly value the security and safety of our premises and staff. To support this, we employ Closed-Circuit Television (CCTV) systems as essential tools in creating a secure and welcoming work environment. This policy outlines our responsible approach to CCTV usage, ensuring compliance with the General Data Protection Regulation (GDPR), UK laws, and our broader data security and privacy commitments.
Policy Scope
This policy applies to all CCTV systems and related recordings used within and around our office locations. It encompasses all areas monitored by cameras to observe and record activities.
Objectives
We use CCTV for the following core purposes:
- To safeguard our physical assets and office spaces.
- To enhance the safety and well-being of all employees and visitors.
3. To deter and prevent unauthorised activities such as theft and
vandalism.
4. To assist in investigating accidents and incidents by providing reliable
evidence when needed.
Nudge Education CCTV and Data Management Policy V1.1 Dec 25 Compliance with Legislation
Our CCTV practices are in full alignment with GDPR and other pertinent legislation. This ensures our surveillance is justifiable, proportionate, and respectful of everyone’s privacy. We make sure our practices are transparent and carried out with fairness.
Data Collection and Fair Use
Transparency: We clearly display signs where CCTV is operational, providing transparency about surveillance and its intent. Purpose Limitation: We do not use CCTV for monitoring staff performance or for any purpose not clearly specified in this policy without explicit justification and communication.
Data Storage and Access
Standard Retention Period: Normally, CCTV footage is kept for 21 days as facilitated by our Hik-Connect system. This duration allows ample time for reviewing footage following any incidents. Extended Retention Conditions: In cases involving potential legal or HR issues, such as accidents or disciplinary matters, relevant footage may be retained as part of our HR records for up to 7 years. Access Control: Access to CCTV footage is strictly limited to authorised personnel, ensuring that privacy and data protection principles are upheld.
Rights of Individuals
Individuals have rights under the GDPR, including the right to access footage in which they are identifiable. We handle access requests promptly and respectfully, in line with legal requirements.
Data Security and Integrity Protection Measures: We employ robust security measures to protect CCTV footage against unauthorised access or misuse. This includes secure storage and, where necessary, encryption. Data Accuracy: We conduct regular checks and maintenance to ensure that our CCTV systems function correctly and record accurately.
Nudge Education CCTV and Data Management Policy V1.1 Dec 25 Data Disposal
Once the standard retention period has elapsed, or after extended retention periods end, CCTV footage is securely deleted. We use methods such as data overwriting or physical destruction of storage media to prevent any possibility of data recovery.
Review and Monitoring
We regularly review this policy to ensure it remains up-to-date with technological, legal, and operational changes. We also welcome feedback from our staff and stakeholders to enhance the effectiveness and sensitivity of our surveillance practices.
By adhering to this policy, Nudge Education is committed to using CCTV in a manner that is both responsible and considerate, balancing security needs with the privacy rights of individuals. We remain dedicated to continuous evaluation and improvement of our surveillance procedures.
Should you have any questions or concerns about our CCTV policy or practices, please do not hesitate to contact our Data Protection Officer at brian.mair@nudgeeducation.co.uk
Version Date Details of Change(s) Approved By 1.1 5/12/2025 Implementation of 1.1 policy Brian Mair
Nudge Education CCTV and Data Management Policy V1.1 Dec 25
Applicability to NEO
This policy is inactive for NEO online provision — NEO is fully online and this policy applies only to face-to-face provision operated by Nudge Education Ltd. It is retained in the vault tagged inactive-neo so commissioners and staff can see explicitly that the policy does not apply to online placements.
Document control
| Field | Value |
|---|---|
| Version | Dec 2025 |
| Owner | Director of Operations |
| Status | live |
| Source file | 4. Office Staff/CCTV Policy - Dec 2025.pdf |