Photographs & Videos

Personal Data can include photographs and videos of living individuals even if they are not named. Remember, personal data includes information about an indentified or identifiable living individual.

This can therefore include everything from CCTV images, to promotions photos, to staff profile pictures.

Please see the guidance below for each main category of photographic or video data:

Surveillance Cameras (CCTV, BWV etc)

It is obvious that any type of Surveillance Cameras are likely to capture and record personal data. Surveillance Cameras will include CCTV, Body Worn Video (BWV), Automatic Number Plate Recognition systems (ANPR), dashboard and covert cameras.

Both the Surveillance Camera Commission and the ICO have published codes of practice governing the use of this technology:

ICO's CCTV Code of Practice

Surveillance Camera Code of Practice

If, as a Keele employee, you are proposing to use any form of Surveillance Camera technology on University premises or on behalf of the University, then you should review the above codes and consult with the DPO and/or the Security Team. In addition it is likely that you will be required by law* to undertake a Data Protection Impact Assessment (DPIA) at the earliest opportunity in the projects design.


* The General Data Protection Regulations / Data Protection Act 2018 may well mandate that a DPIA is required for Surveillance type operations.

Capturing Photos/Videos - Guidance

For guidance on when consent is needed for the capture and storage of images, together with a template form, please download the University's Image Guidance.