CCTV & GDPR Compliance for UK Businesses: What You Must Do to Stay Legal

CCTV is one of the most effective security tools available to businesses today. It deters crime, protects staff and property, and provides valuable evidence when incidents occur.

However, CCTV also captures personal data, which means its use is tightly regulated under the UK GDPR and the Data Protection Act 2018.

Many businesses install CCTV with the best intentions — but without the correct policies, settings, and controls in place, they may be unintentionally non-compliant, leaving themselves exposed to complaints, enforcement action, and reputational damage.

At Phantom Communications Ltd, we help businesses install and manage CCTV systems that are not only effective, but fully compliant.

This guide explains what UK GDPR means for CCTV, and what you need to have in place to remain compliant.

Does GDPR Apply to CCTV?

Yes — almost always.

If your CCTV system captures images of identifiable individuals outside of a purely domestic setting, it falls under UK GDPR. This includes:

• Shops and retail premises

• Offices and commercial buildings

• Warehouses and industrial sites

• Farms and agricultural businesses

• Caravan parks and leisure sites

• Schools, care homes, and public-facing premises

Even if CCTV is installed purely for security, it still processes personal data and must comply with the law.

Lawful Basis for Using CCTV

Under UK GDPR, you must have a lawful basis for processing personal data.

For most businesses, CCTV is justified under:

Legitimate Interests

You must be able to show that:

• CCTV is necessary for a genuine purpose (e.g. preventing theft, protecting staff, securing assets)

• The system is proportionate

• Individuals’ rights are not overridden

You should be able to clearly explain why CCTV is needed and why less intrusive methods would not achieve the same outcome.

This justification should be documented.

Transparency: Letting People Know CCTV Is in Use

One of the most common compliance failures we see is poor or missing signage.

You must:

• Display clear and visible CCTV warning signs

• Use signs before people enter the monitored area

• Include:

  • That CCTV is in operation

  • The purpose (e.g. “for crime prevention and public safety”)

  • Who operates the system (the business name)

This is a legal requirement — not optional.

Data Protection Impact Assessment (DPIA)

In many cases, businesses should complete a Data Protection Impact Assessment (DPIA) before installing CCTV.

A DPIA helps you:

• Identify privacy risks

• Justify camera placement

• Demonstrate accountability

A DPIA is especially important if:

• Cameras monitor public areas

• Cameras cover entrances/exits

• There is extensive or continuous monitoring

• The site is high-risk or high-traffic

Phantom Communications can advise when a DPIA is required and what it should cover.

Camera Placement & Field of View

CCTV must be proportionate.

You should:

• Only monitor areas necessary for security

• Avoid filming:

  • Public roads (unless unavoidable)

  • Neighbouring properties

  • Private residential spaces

• Avoid intrusive coverage of staff areas unless strictly necessary

This is where privacy masking becomes essential.

Privacy Masking: A Key Compliance Tool

Privacy masking allows parts of the camera image to be permanently obscured.

Privacy masking should be used to:

• Block neighbouring properties

• Mask public footpaths or roads

• Prevent coverage of residential windows

• Reduce unnecessary capture of personal data

Masks must:

• Be fixed (not removable by operators)

• Apply to live view and recorded footage

Modern CCTV systems support advanced masking features, and we configure these correctly at installation to ensure compliance from day one.

Audio Recording & CCTV

Audio recording is far more intrusive than video and carries a significantly higher compliance risk.

Key points:

• Audio recording is rarely justified for security

• In most business environments, audio should be disabled

• Recording conversations can breach:

  • UK GDPR

  • Human Rights legislation

  • Employment law

Our standard practice at Phantom Communications is:

• Audio recording disabled by default

• Only enabled where there is a very clear, lawful justification

• Fully documented and clearly signed if used

For most businesses, audio recording is not recommended.

Access Control: Who Can View CCTV?

Access to CCTV footage must be strictly controlled.

You must:

• Limit access to authorised individuals only

• Use strong passwords and user permissions

• Keep a log of who can access the system

• Prevent unauthorised remote viewing

Allowing unrestricted access — or sharing login details — is a serious compliance risk.

Storage, Retention & Deletion

CCTV footage must not be kept for longer than necessary.

Typical retention periods:

• 14–31 days for most businesses

• Longer only if justified (e.g. high-risk sites)

You should:

• Set automatic overwrite periods

• Retain footage longer only if required for an incident or investigation

• Securely delete footage when no longer needed

Retention policies should be documented.

Subject Access Requests (SARs)

Individuals have the right to request copies of footage showing them.

You must:

• Respond within one month

• Provide footage in a secure format

• Blur or mask other individuals where necessary

• Verify identity before releasing footage

Poor system configuration can make SARs difficult or impossible — another reason professional setup matters.

Why Old CCTV Systems Are Often Non-Compliant

Many older CCTV systems:

• Lack privacy masking

• Do not support secure user permissions

• Have no retention controls

• Record audio by default

• Use outdated firmware or insecure remote access

Even if the system still “works”, it may not be fit for purpose under GDPR.

Upgrading to a modern system is often the safest and most cost-effective way to ensure compliance.

How Phantom Communications Ensures Compliance

At Phantom Communications Ltd, compliance is built into everything we do.

We:

• Design CCTV systems with GDPR in mind

• Configure privacy masking correctly

• Disable unnecessary audio recording

• Set appropriate retention periods

• Secure systems with proper access controls

• Advise on signage, policies, and documentation

• Offer surveys and system reviews for existing installations

Our goal is simple: effective security without unnecessary risk.

Need a CCTV Compliance Check?

If you already have CCTV installed or are considering a new system, a professional review can identify risks before they become problems.

We offer free CCTV surveys and compliance advice for businesses and homeowners across North Wales and beyond.