CCTV and Audio Recording Policy

1. Purpose of this policy

Redline Buses and Red Rose Travel use CCTV systems on our buses to help protect passengers, drivers, employees, vehicles and members of the public.

CCTV systems may also operate at some of our premises.

Our buses contain a number of CCTV cameras. Not all cameras record audio.

Certain audio-enabled cameras are situated at the front of the vehicle, including in or around the driver’s cab and the front passenger interaction area. These cameras record audio as well as video.

This policy explains why CCTV and audio recordings are made, how long they are retained, how they may be used and the rights individuals have in relation to recordings containing their personal information.

2. Why we use CCTV

  • protecting passengers, drivers, employees and members of the public
  • deterring and investigating crime and antisocial behaviour
  • investigating assaults, threats and abusive behaviour
  • investigating accidents and road traffic collisions
  • investigating significant passenger complaints
  • establishing what occurred where accounts of an incident differ
  • protecting vehicles and other property
  • preventing and investigating fraud
  • assisting the police and other competent authorities where appropriate
  • supporting insurance and legal claims
  • improving the safety of our operations

3. Where audio is recorded

Audio is not recorded by every CCTV camera on our buses.

Audio recording is limited to certain cameras situated at the front of the vehicle, including in or around the driver’s cab and the area where passengers communicate and interact with the driver.

Other CCTV cameras used to monitor the passenger saloon or other parts of the vehicle may record video without audio.

The precise camera configuration may vary between vehicles.

4. Why audio is recorded

The purpose of audio recording at the front of the vehicle is to provide an accurate evidential record of interactions and incidents involving the driver and passengers where spoken words may be directly relevant.

Audio may be particularly important when investigating:

  • assaults or attempted assaults
  • threats or intimidation
  • abusive or aggressive behaviour
  • other suspected criminal activity
  • disputes between passengers and drivers
  • allegations concerning what was said during an incident
  • serious safety incidents
  • road traffic collisions and events immediately before or after a collision
  • incidents that may result in police, insurance or legal investigations

Video footage alone may show what occurred physically but may not establish what was said, whether threats or warnings were made, instructions given, or the circumstances leading to an incident.

For this reason, designated cameras at the front of the vehicle around the driver/passenger interaction area may record both video and audio. Audio provides additional evidential context where the conduct, words or warnings of the driver or passenger may be relevant to a criminal investigation, road traffic collision, safety investigation, complaint, insurance matter or legal claim.

5. Limits on our use of audio

We recognise that recording conversations is more intrusive than video-only CCTV.

We therefore limit audio recording to the cameras and areas where we consider there is a particular safety, security or evidential need. Audio is not intended to be recorded throughout the vehicle.

Audio recording is not intended for the routine listening to or monitoring of ordinary passenger conversations.

Access to audio will only take place where there is a legitimate reason to review the relevant recording, such as:

  • an accident or road traffic collision
  • a reported crime
  • an allegation of threatening or abusive behaviour
  • a serious passenger complaint
  • a safety incident
  • an insurance claim
  • an employment or disciplinary investigation arising from a specific incident
  • a legal claim
  • a request from the police or another competent authority
  • another legitimate and proportionate investigation

Recordings must not be accessed merely out of curiosity or for general surveillance of passenger conversations.

6. Lawful basis

Our principal lawful basis for processing CCTV and audio recordings is our legitimate interests.

  • protecting the health and safety of passengers and employees
  • protecting drivers who may be exposed to abuse, threats or assault while carrying out their duties
  • protecting passengers and members of the public
  • detecting and investigating criminal activity
  • investigating accidents and road traffic collisions
  • establishing the facts surrounding incidents
  • protecting our vehicles and property
  • establishing, exercising or defending legal and insurance claims

Where processing is necessary to comply with a specific legal obligation or lawful requirement, another appropriate lawful basis may apply.

We regularly review the necessity and proportionality of our CCTV and audio arrangements.

7. Responsibility for recordings

For recordings made on a bus operated by Redline Buses, the data controller will normally be Red Line Buses Ltd, company number 08758110.

For recordings made on a bus operated by Red Rose Travel, the data controller will normally be Red Rose Travel Limited, company number 02945744.

Further contact and registered-office information is available in our Privacy Notice and Legal and Operator Information.

8. CCTV and audio signage

Our vehicles display CCTV notices informing passengers that surveillance is in operation.

Where the CCTV system includes audio recording, passengers will be informed that video is recorded and that audio is also recorded by designated cameras at the front of the vehicle around the driver/passenger interaction area.

Passengers can obtain further information about how recordings are used by referring to this policy and our Privacy Notice.

9. When recordings are viewed

CCTV and audio recordings are not routinely watched or listened to simply because they have been recorded.

Recordings may be reviewed by authorised persons where there is a legitimate reason, including:

  • investigating an accident or road traffic collision
  • investigating a crime or suspected criminal offence
  • investigating an assault, threat or abusive incident
  • investigating a serious complaint
  • investigating a safety-related incident
  • dealing with an insurance claim
  • establishing or defending a legal claim
  • responding to an appropriate request from the police
  • responding to a data-protection request
  • investigating a specific employment matter where the recording is relevant

Access is restricted to persons who require the recording for an authorised purpose.

10. Retention

Routine onboard CCTV recordings, including audio from audio-enabled cameras, are normally retained for approximately three weeks (21 days).

After approximately 21 days, recordings are automatically overwritten as part of the normal recording cycle.

If we become aware that footage relates to an incident before it is overwritten, the relevant footage may be extracted and preserved.

For example, footage may be preserved in connection with:

  • a road traffic collision
  • an accident or injury
  • a criminal investigation
  • an assault or threatening incident
  • a serious complaint
  • a police request
  • an insurance claim
  • legal proceedings
  • another specific investigation

Extracted recordings will be retained only for as long as reasonably necessary for the purpose for which they were extracted and any associated legal, regulatory or insurance requirements.

11. Road traffic collisions

CCTV and, where available, audio recordings may be preserved following a road traffic collision.

Recordings may be used to:

  • establish how the collision occurred
  • identify events immediately before or after the collision
  • establish communications involving the driver
  • identify warnings, instructions or statements made immediately before or after the collision
  • assist internal accident investigations
  • assist insurers or claims handlers
  • assist the police where appropriate
  • establish, exercise or defend legal claims

Relevant footage may therefore be retained beyond the normal three-week overwrite period when a collision or potential claim is being investigated.

12. Criminal activity

Where CCTV or audio appears to contain evidence of criminal activity, the relevant recording may be preserved and disclosed to the police or another competent law-enforcement authority where it is lawful and appropriate to do so.

This may include evidence relating to:

  • assault
  • threats
  • harassment
  • criminal damage
  • theft
  • fraud
  • dangerous behaviour
  • other suspected offences

13. Sharing recordings

Recordings may be shared where necessary, proportionate and lawful with organisations including:

  • police and other law-enforcement authorities
  • courts and tribunals
  • insurers
  • insurance claims handlers
  • solicitors and other professional advisers
  • regulatory authorities
  • local or central government authorities
  • other persons where disclosure is required or permitted by law

Before footage is disclosed, we will consider whether disclosure is lawful and whether the rights of other identifiable individuals need to be protected.

14. Requests from the police

We may provide CCTV and audio recordings to the police where we receive an appropriate request and are satisfied that there is a lawful basis for disclosure.

The fact that the police request footage does not remove our responsibility to consider whether disclosure is lawful and appropriate.

15. Requests from passengers and other individuals

Individuals may have the right to request access to personal information contained in CCTV and audio recordings.

Because routine footage is normally overwritten after approximately three weeks, requests should be submitted as soon as possible.

To help us locate a recording, please provide as much of the following information as possible:

  • the date
  • approximate time
  • bus route
  • direction of travel
  • boarding or alighting location
  • vehicle registration or fleet number, if known
  • a description of the incident
  • information that will enable us to identify you within the recording

We may ask for proof of identity.

Where a recording contains personal information relating to other people, we will consider their rights before releasing it. This may require images to be obscured, audio to be edited or portions of a recording to be withheld where permitted by law.

16. Recordings involving employees

CCTV cameras at the front of the vehicle and around the driver’s cab necessarily record our drivers and may record conversations between drivers and passengers.

Recordings are not intended to be routinely accessed for continuous employee-performance monitoring.

However, relevant CCTV and audio may be reviewed where necessary to investigate a specific:

  • safety incident
  • road traffic collision
  • complaint
  • allegation
  • criminal matter
  • insurance claim
  • breach of company procedures
  • disciplinary matter

Any such use will be undertaken in accordance with applicable data-protection and employment requirements.

17. Security

CCTV and audio recordings must be protected against unauthorised access, disclosure, alteration or loss.

Access to the recording system is restricted to authorised personnel.

Recordings must not be copied, downloaded, shared or published except for an authorised and legitimate purpose.

Employees accessing CCTV are required to comply with our internal data-protection and CCTV procedures.

18. Data Protection Impact Assessment

Because audio recording is more intrusive than video-only surveillance, we assess the necessity, proportionality and privacy risks associated with audio-enabled cameras.

Our assessment takes account of matters including:

  • the safety of our drivers
  • the nature and frequency of incidents occurring onboard buses
  • the risk of verbal and physical abuse
  • the evidential requirements following criminal incidents
  • road traffic collision investigations
  • the fact that audio-enabled cameras are limited to the front of the vehicle around the driver/passenger interaction area rather than throughout the passenger saloon
  • whether less intrusive measures could reasonably achieve the same purpose
  • access restrictions
  • the three-week routine retention period
  • the rights and reasonable expectations of passengers and employees

We keep our CCTV and audio arrangements under review.

19. Complaints and data-protection rights

If you have concerns about our use of CCTV or audio recording, please contact us using the contact details published on our website.

Please identify your enquiry as a Data Protection / Privacy matter where appropriate.

Further information about your data-protection rights and how to complain to us or the Information Commissioner’s Office is contained in our Privacy Notice.

20. Review of this policy

We may update this policy if our CCTV systems, operating arrangements or legal requirements change.

The current version will be published on the Red Group website.