It surrounds the use of CCTV cameras which are in operation on a multi storey car park. There are numerous signs up saying “CCTV Surveillance in operation” on the first floor where there is access to and from the car park. In addition, there are signs in the stairwell where there is pedestrian access to and from. My question is whether those CCTV cameras can legitimately be used to observe behaviour of security staff who patrol the car park ie whether they are properly carrying out their duties at the correct times or whether they are spending excessive time relaxing. Below is an extract from a set of procedures which has been issued to car park staff:-

In accordance with the Car Park CCTV Code of Practice, Security Supervisors must not use the CCTV System to monitor the movement/deployment of colleagues except when providing support to the security and car park staff on their day to day patrols. Any concerns about the conduct of colleagues in this matter, must, in the first instance, be brought to the attention of the Car Park Manager or the Assistant Civil Parking Enforcement Manager who may authorise a review of the images stored on the CCTV system hard drive and the subsequent copying and storage of these images.

Given this procedure gives the Manager authority to review the images, this would undoubtedly determine whether he had cause for concern. On the assumption that he has concern, is it reasonable for him to authorise use of the CCTV cameras to obtain further evidence of non-compliance with procedures? Does the law allow him to do so?

I look forward to your response. If you have any questions in relation to this please don’t hesitate to contact me.

Kind Regards