Your vehicle can only be fitted with a UK approved, GDPR compliant CCTV system that can record video images and switch controlled audio recordings. You cannot use a dashcam to record the inside of your vehicle.
Description of a system
A system means any electronic recording device that can be attached to the inside of your vehicle. It will be able to capture and store visual images and audio recordings from inside or outside of the vehicle.
To be considered suitable to be fitted in your vehicle, your CCTV must meet the requirements listed below.
General system requirements
Once your system has been installed, it must always be in operation whilst your vehicle is being used as a licensed taxi. You do not need to use the system when the vehicle is being used for personal or domestic purposes.
About CCTV
All CCTV equipment must conform to our standards and data protection legislation. We will not approve your CCTV system if it doesn’t meet these standards.
We will inspect CCTV systems as part of our compliance test. This will tell us whether your system has been safely and securely installed.
The design, construction and fitting of your CCTV must not in any way present a danger to either driver or passengers. This includes any damage caused by:
- vandalism
- misuse
- general wear and tear
Installation and operation of CCTV
When you install and use your CCTV system, you must comply with the Information Commissioner’s Officer’s CCTV Code of Practice.
Your equipment must meet the following requirements:
- safety
- construction and use
- technical acceptability
- operational and data integrity
CCTV signage
You must display notices in your licensed vehicle telling passengers that:
- CCTV is in operation which may include audio within the vehicle
- they may be recorded
These notices must be placed in both the front and back of your vehicle.
Audio recording methods
Audio recording must be active where:
- a child is on their own, or a vulnerable adult is travelling in the vehicle
- the driver and passenger are involved in a dispute
- the driver feels threatened by the behaviour of the passenger
- there is any other such event that needs to be recorded
The audio recording must be started by either yourself or the passenger pressing a switch. Once it has started, the recording will continue until the switch is pressed again to stop it. These switches must be independent of each other.
There must be something in the vehicle that tells the passenger that the audio recording is taking place. The passenger must be able to clearly see this. For example, it could be built into the switch.
At the end of a journey, the audio recording must stop when the passenger leaves your vehicle. It must not continue when a new passenger enters and starts a new journey.
However, there should be a way of starting a new audio recording if any of the issues we have described above take place during this new journey.
Automotive electromagnetic compatibility requirements
Your system must not interfere with the following functions of your vehicle:
- safety
- control
- electrics
- computer
- navigation
- satellite or radio system
All CCTV equipment must be CE-marked.
CCTV security
All images taken by your CCTV must be stored securely and not accessible to others. They must be protected, encrypted and stored away from the camera itself. You can get advice from the Information Commissioner’s Office (ICO) about how to keep personal data secure (including personal data stored in CCTV).
Registering with the Information Commissioner’s Office
The ICO is the UK’s independent organisation that has been set up to manage information and data protection rights.
Data controller
The Data Protection (Charges and Information) Regulations 2018 and UK GDPR state that if you store, use or process personal information, you must register as a ‘data controller’. To do this, you must pay a data protection fee to the ICO.
There may be some cases where you do not have to pay the fee to the ICO. If you want to register as a data controller, you will need to provide a copy of your registration certificate to us and the installer of your CCTV.
Only registered data controllers can access stored data. If you are not registered, then you will not be able to directly access any recordings.
If you have registered as a data controller
You will need to tell us that you have registered as a data controller with the ICO. When you do this, you will also need to know your:
- vehicle details
- CCTV manufacturer
- CCTV installer
Data management
Downloads
Data will only be downloaded where:
- a crime has been reported that involved your licensed vehicle and the police have formally asked for the data
- where a complaint has been made to us about you or your vehicle
- we receive a data request from an organisation such as the police or social services, that needs to access data to help them with an investigation about you or your vehicle
- we receive a Subject Access Request that complies with the Data Protection Act
Retention periods
Data will be retained by us for the following periods:
| Reason | Retention Period |
|---|---|
| Cases leading to prosecution | 10 years from the date of trial |
| Formal caution | 3 years from the date of caution |
| Written warning or no formal action | 3 years from date of decision |
| Subject Access Request | 6 years from date of request |
More information
For more information about image and sound recording, see Appendix A of our Private Hire Operator and Vehicle Licence policy.