CCTV & Biometric Monitoring in Clinical Areas
Where cameras and biometric readers may and may not go in a hospital, what notice is required, how long footage is kept, and who can view it. Clinical areas raise a dignity problem that a generic CCTV policy does not address.
# CCTV & Biometric Monitoring in Clinical Areas
**[HOSPITAL_NAME]** — implements DPDP Act 2023 **s.5** (notice), **s.8(5)**
(reasonable security safeguards), **s.8(7)** (erasure once the purpose is
served) and **s.4** (lawful basis) for camera and biometric systems.
## 1. Why hospitals need more than a generic CCTV policy
A camera in a corridor is a security measure. A camera that can see into a
consultation room, a ward bay, a labour room or a changing area is
capturing clinical and bodily information about identifiable patients at
their most exposed. The data category is different, the harm is different,
and the location decision has to be made deliberately rather than by
wherever the installer found a convenient wall.
## 2. Camera placement
| Area | Camera permitted? | Notes |
|---|---|---|
| Entrances, exits, corridors, lifts, parking | Yes | Standard security purpose |
| Reception, waiting areas, billing counters | Yes | Avoid framing that captures documents or screens showing patient details |
| Pharmacy, stores, cash handling | Yes | Asset protection |
| ICU / high-dependency, where used for **clinical observation** | [CUSTOMIZE — decide and justify] | If used, this is clinical monitoring, not security: restrict access to clinical staff, state the purpose in the notice, and treat the footage as clinical data |
| General wards / ward bays | [CUSTOMIZE — justify each camera individually] | Beds, curtained bays and treatment being administered must not be in frame |
| Consultation rooms, examination rooms | **No** | [CUSTOMIZE if you believe an exception applies — document who approved it, the purpose, and how patient dignity is protected] |
| Labour rooms, operation theatres | **No**, except [CUSTOMIZE: theatre recording for a specific clinical or teaching purpose, with its own consent — see `hospital-consent-separation`] | Never on a general security feed |
| Toilets, bathing areas, changing rooms | **No.** Never | No purpose justifies this |
| Staff rest areas | [CUSTOMIZE — generally no] | |
For each camera record: location, what is in frame, purpose, who can view
it, retention. **[CUSTOMIZE: complete the camera register. A hospital that
cannot say what each camera sees cannot claim it controls the footage.]**
Do a physical walkthrough of what each camera can actually see, monitor by
monitor — not what the floor plan suggests. Cameras get moved, and a
repositioned camera is a new processing activity nobody documented.
## 3. Notice (s.5)
Signage at every monitored area entrance, in English and
[CUSTOMIZE: local language], stating: that the area is monitored, the
purpose, who operates it, how long footage is kept, and how to contact the
Grievance Officer. Reference the camera system in the patient privacy
notice.
Signage after the fact is not notice. A camera installed before its sign
was put up processed data without notice, and that is worth recording
honestly rather than backdating.
**Ready-to-print sign (English):**
> **CCTV MONITORING IN PROGRESS** — for [CUSTOMIZE: purpose].
> Operated by [HOSPITAL_NAME]. Recordings are kept for
> [CUSTOMIZE: number] days and then deleted.
> Contact: [CUSTOMIZE: Grievance Officer], [CUSTOMIZE: phone/email].
**छपाई हेतु सूचना (हिन्दी):**
> **सीसीटीवी निगरानी जारी** — [CUSTOMIZE: उद्देश्य] हेतु।
> संचालक: [HOSPITAL_NAME]। रिकॉर्डिंग [CUSTOMIZE: संख्या] दिन तक रखी जाती
> है, तत्पश्चात हटा दी जाती है।
> संपर्क: [CUSTOMIZE: शिकायत निवारण अधिकारी], [CUSTOMIZE: फोन/ईमेल]।
## 4. Access and viewing
- Live viewing: [CUSTOMIZE: roles].
- Reviewing recordings: [CUSTOMIZE: roles]. Every review is logged —
who, when, which camera, what period, and why.
- Export / copy: [CUSTOMIZE: approving role only]. Log every export.
- Disclosure to police or a court: only against a written requisition;
record what was given, to whom, under which provision, and who approved.
- Where ICU footage is used clinically, access is restricted to clinical
staff — not the security desk.
**[CUSTOMIZE: confirm who can physically reach the DVR/NVR and whether the
default admin password was changed.]** An unsecured recorder in an
unlocked room is a s.8(5) failure regardless of what this policy says.
## 5. Retention (s.8(7))
- Footage retained for [CUSTOMIZE: number] days, then automatically
overwritten. Days, not years — the security purpose is served quickly.
- **Verify the recorder's actual configured retention.** Read it off the
device and record the figure. Recorders are routinely configured to keep
far more or far less than the policy claims, and the device setting is
what governs, not this document.
- Clips retained beyond the standard period (incident, claim, medico-legal
case) go in a register with reason, owner and disposal date.
- ICU/clinical footage: retention per [CUSTOMIZE], treated as clinical
data under `hospital-records-retention`.
## 6. Biometric systems
Biometric data is sensitive, and in the existing DPDPA scoping rules
holding it is one of the indicators that points to Significant Data
Fiduciary status. Treat it accordingly.
| System | Whose data | Purpose | Where template stored | Retention |
|---|---|---|---|---|
| Staff attendance | Staff | [CUSTOMIZE] | [CUSTOMIZE: on-device / vendor cloud] | [CUSTOMIZE] |
| Restricted-area access (pharmacy, records, theatre) | Staff | [CUSTOMIZE] | [CUSTOMIZE] | [CUSTOMIZE] |
| Patient identification, if used | Patients | [CUSTOMIZE] | [CUSTOMIZE] | [CUSTOMIZE] |
For each: notice given to the person enrolled, whether a non-biometric
alternative exists, whether the raw image or only a derived template is
stored, and deletion on exit. **[CUSTOMIZE: confirm biometric records are
deleted when a staff member leaves — this is the step almost always
missed, and a former employee's fingerprint template sitting in a device
years later is straightforwardly unlawful retention under s.8(7).]**
The device vendor is a Data Processor if templates leave the device — cover
them in `hospital-vendor-assessment`.
## 7. Evidence to upload to Sentyra
- The completed camera register and a photo of the signage in place.
- A screenshot or photo of the recorder's configured retention setting.
- The access/review log for the current period.
- The biometric enrolment and deletion log.
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*Owner: [ROLE] · Review: [ANNUALLY] · Version: [VERSION] · Date: [DATE]*