1. Purpose
This policy sets out Murzo Group's approach to CCTV, surveillance systems, body-worn cameras, monitoring technologies, recorded images, audio, and related personal data.
The purpose is to ensure any surveillance is lawful, fair, proportionate, transparent, necessary, secure, and limited to legitimate purposes.
2. Scope
This policy applies where Murzo Group uses, commissions, controls, accesses, or receives CCTV, video surveillance, body-worn camera footage, doorbell cameras, dash cameras, site cameras, remote monitoring, security footage, or similar recordings.
It applies to offices, sites, storage areas, fieldwork, events, vehicles, client sites, supplier sites, and public-facing activity where Murzo Group has responsibility or influence.
3. Permitted Purposes
Surveillance may only be used for defined and legitimate purposes.
- Protecting health, safety, security, people, visitors, products, equipment, premises, assets, and confidential information
- Preventing, detecting, or investigating theft, fraud, violence, unauthorised access, tampering, sabotage, vandalism, or serious misconduct
- Supporting incident investigation, insurance claims, legal claims, product security, or authority requests
- Managing access control, delivery areas, high-risk activities, or lone working where proportionate
- Complying with legal, contractual, insurer, or site-security requirements
4. Privacy & Proportionality
Murzo Group will consider privacy impact before using surveillance, especially where monitoring may capture workers, visitors, the public, private areas, audio, sensitive activity, or vulnerable people.
Surveillance must not be excessive, covert, unnecessarily intrusive, or used for unrelated purposes. Covert surveillance may only be considered in exceptional circumstances with senior approval and legal review.
5. Transparency & Signage
Where practicable and lawful, people should be informed that surveillance is in use through signage, notices, contracts, visitor information, staff information, or other suitable communication.
Information should explain who is responsible, why recording is taking place, and how to contact Murzo Group about the recording.
6. Body-Worn Cameras
Body-worn cameras may be used only where justified by security, safety, evidence, lone working, conflict management, delivery, site access, or incident-response needs.
Users must understand when recording is permitted, when to stop recording, how to announce recording where appropriate, how to protect footage, and how to report incidents involving body-worn camera use.
7. Audio Recording
Audio recording is more intrusive than image recording and should only be used where necessary, proportionate, justified, and approved.
Routine audio recording in areas where people expect private conversation should be avoided unless there is a clear lawful basis and strong justification.
8. Access, Storage & Retention
Recordings must be stored securely, protected from unauthorised access, and retained only for as long as necessary for the purpose for which they were captured unless required for investigation, legal claim, insurance, authority request, or safeguarding.
Access should be limited to authorised people and activity should be logged where practicable.
9. Disclosure & Subject Rights
Murzo Group may disclose footage to law enforcement, regulators, insurers, legal advisers, customers, suppliers, or other parties where lawful, necessary, proportionate, and properly authorised.
Requests from individuals to access footage showing them must be handled in line with data protection requirements and may require identity checks, redaction, or refusal where another lawful reason applies.
10. Records, Review & Responsibilities
Murzo Group will keep appropriate records of surveillance purposes, locations, privacy assessments, retention rules, access decisions, disclosure decisions, incidents, and reviews.
Managers, site leads, security contacts, system owners, and authorised representatives are responsible for applying this policy. It will be reviewed periodically and when surveillance technology, sites, legal requirements, or risk levels change.
