When Starting Recording
Example:
I am switching on my body-worn camera because of the behaviour taking place. It will record our interaction.
Where appropriate, add:
The recording will be managed in accordance with our organisation's policy.

This guidance is for employers, managers, health and safety professionals, data protection officers and others responsible for introducing or managing body-worn cameras.
It is particularly relevant to housing associations, local authorities, enforcement teams, security services, healthcare, social care, charities and other public-facing organisations.
Employees who wear cameras also need to understand when recording is permitted, how to activate equipment safely, what to say and what happens to footage afterwards.
The organisation must establish the lawful purpose and operating procedures. Employees should not be expected to make complex legal decisions during a threatening encounter.
The applicable legal requirements depend on the country, organisation and activity. Employers in the United Kingdom and the Republic of Ireland must consider the data protection and other legislation that applies to them.
This guide explains:
This guide concerns cameras issued or operated by employers.
For advice about residents or members of the public filming employees, see When Staff Are Recorded or Livestreamed.
For online threats, exposure of staff identities and digital footprints, see Protecting Staff from Online Targeting and Harassment.
An organisation should begin by establishing why cameras are needed and what problem they are intended to address.
Body-worn cameras may help provide evidence of threats, violence, serious confrontations or disputed incidents.
However, they do not prevent every incident and must not replace effective risk assessments, appropriate staffing, communication skills, lone worker procedures or emergency arrangements.
Recording must have an appropriate lawful purpose and be necessary and proportionate.
Review incident reports, risk assessments, complaints, staff concerns and the circumstances in which recordings would provide a genuine benefit.
Consider whether alternative measures, such as safer reception arrangements, changes to visiting procedures, additional staff or personal safety alarms, would address the risk.
Cameras should not be introduced simply because the technology is available.
Before equipment is issued, the organisation must establish how recordings will be managed, who may access them and what safeguards will protect the people being recorded.
Depending on the organisation's approved policy, recording may be justified when:
These are examples, not automatic permission to record.
An ordinary enquiry, disagreement or complaint does not necessarily justify recording.
Employees must follow their organisation's authorised activation rules and training.
Recording may be inappropriate where there is no identified need or where it would unnecessarily intrude on someone's privacy.
Additional care is needed when recording could capture confidential conversations, medical information, children, vulnerable people or sensitive circumstances in a person's home.
Organisations should establish clear restrictions and identify situations requiring additional authorisation.
Staff should not use a body-worn camera to record private disagreements, monitor colleagues informally or gather unrelated information.
Employers should be able to explain:
Do not issue cameras before the organisation has established the lawful purpose, appropriate privacy safeguards, staff procedures, storage arrangements and responsibilities for handling footage.
A controlled pilot may help confirm whether the equipment and procedures work before wider introduction.
The organisation should be satisfied that the cameras meet a genuine need and can be managed safely and lawfully.
Body-worn cameras can capture identifiable people, conversations and other personal information.
Employers must establish an appropriate lawful basis for recording and comply with the data protection legislation that applies to their organisation.
In the United Kingdom, the relevant framework includes the UK General Data Protection Regulation and the Data Protection Act 2018.
In the Republic of Ireland, the European Union General Data Protection Regulation and Irish Data Protection Act 2018 apply.
The lawful basis and any additional processing conditions depend on the organisation, purpose and information captured.
Consent should not automatically be assumed to be the appropriate lawful basis.
Video, audio, names, locations and identifiers are personal data. Consent is rarely a sound basis for routine recording of staff or the public. People cannot freely refuse a camera on a visit they did not choose. A public authority may rely on public task where its functions have a clear basis in law. A private organisation may consider legitimate interests, with a recorded balancing test. Since 5 February 2026, a private organisation may instead consider recognised legitimate interests where recording is necessary for a purpose listed in Annex 1 to the UK General Data Protection Regulation, such as detecting or preventing crime, or safeguarding a vulnerable individual. That basis needs no balancing test, but the recording must still be necessary, people must be told which condition you rely on, and public authorities cannot use it for their tasks. Do not later use footage for a different purpose without checking that this is allowed.
Footage may show health, disability, race, religion, sexuality, trade-union activity, biometrics or alleged offending. Identify any extra condition for special category data. For criminal offence data, identify official authority or a Data Protection Act 2018 Schedule 1 condition. An appropriate policy document may also be required. The right to respect for private and family life in the Human Rights Act 1998 still matters in homes, care and welfare settings.
Scotland and Northern Ireland follow the UK General Data Protection Regulation and the Data Protection Act 2018, with their own policing and some sector rules. Do not copy Information Commissioner's Office wording onto an Irish privacy notice.
Before introducing cameras, organisations should complete a data protection impact assessment in line with the Information Commissioner's Office guidance.
The assessment should explain why recording is necessary, who may be affected, what privacy risks arise and how those risks will be reduced.
Where a high risk cannot be adequately reduced, consultation with the relevant regulator may be necessary.
Information Commissioner's Office body-worn video guidance, checked 31 October 2026, is still marked under review because of the Data (Use and Access) Act. It may change. Check the live ICO position during the impact assessment and at each policy review.
People should receive clear information about when and why recording may take place.
This may include visible cameras, recording indicators, notices, written privacy information and appropriate verbal announcements.
Employees must know what to do if making an announcement would create an immediate safety risk.
Omitting an announcement during an immediate threat, where the documented procedure permits this, should not automatically be confused with a separate programme of covert surveillance.
Video and audio recording each require justification.
Audio may capture confidential conversations and sensitive information that would not otherwise appear in an image.
Where appropriate, organisations should consider whether the equipment can control video and audio separately.
Employees must understand exactly what their device records.
Continuous recording is particularly intrusive and requires strong justification.
The policy should identify when recording may begin, when it should stop and when it is prohibited.
Some cameras can save footage from the period immediately before activation. This capability must be considered in the organisation's privacy assessment.
Additional care is required in homes, bedrooms, healthcare settings, treatment areas, confidential meetings and situations involving children or vulnerable people.
Employers should establish restrictions where recording is inappropriate or requires additional authorisation.
Staff should not assume that because a camera is available, recording is permitted in every setting.
Secret monitoring creates significant privacy and legal concerns.
It is not an ordinary body-worn camera safety arrangement.
Any proposed covert monitoring requires separate specialist assessment, appropriate authorisation and compliance with the applicable law.
Employees must not independently use employer-issued cameras to secretly monitor colleagues.
Typical Information Commissioner's Office limits for covert monitoring of workers are suspected criminal activity or gross misconduct, where telling workers would get in the way of prevention or detection. There must be senior authorisation, a data protection impact assessment, a tightly targeted and time-limited plan, and no use in toilets, changing rooms or other places where privacy is reasonably expected.
Additional obligations may apply to surveillance, safeguarding, confidentiality, employment, equality and evidence handling.
The Surveillance Camera Code of Practice applies to specified relevant authorities in England and Wales. It does not automatically apply to every housing association, charity or private employer.
Under section 33 of the Protection of Freedoms Act 2012, relevant authorities in England and Wales, such as local authorities and chief officers of police, must have regard to the Code. A failure to follow it does not of itself create criminal or civil liability, but the Code is admissible in evidence.
Police-specific camera activation rules should not automatically be applied to civilian employees.
Ordinary frontline employees do not acquire police powers simply because they wear a body-worn camera.
The Regulation of Investigatory Powers Act and the Investigatory Powers Act covert surveillance powers are a separate public-body regime. Switching a safety camera to silent does not give a housing association those powers. The Police and Criminal Evidence Act is not a general housing power.
From 30 October 2026, employers in England, Wales and Scotland must take all reasonable steps to prevent sexual harassment of employees.
The Employment Rights Act 2025 also introduced employer liability for qualifying third-party harassment where the employer failed to take all reasonable steps to prevent it.
These changes concern harassment within the Equality Act 2010 and do not automatically cover every abusive incident.
These particular amendments do not apply to Northern Ireland or the Republic of Ireland.
Body-worn cameras may form part of an appropriate prevention strategy, but providing cameras does not automatically satisfy an employer's legal responsibilities.
Legal references: Equality Act 2010, sections 40 and 40A, as amended by sections 20 and 21 of the Employment Rights Act 2025 opens in a new tab. These amendments came into force on 30 October 2026 in England, Wales and Scotland.
For statutes in more depth, use the Workplace Safety Legislation Guide.
Employees should understand why cameras are being introduced, when recording is allowed and how footage may be used.
Consult staff and their representatives before finalising the policy.
Explain who may access footage, when recordings may be reviewed and whether they could be used during complaints, investigations or disciplinary proceedings.
Monitoring employees must be lawful, necessary and proportionate.
Cameras introduced to improve staff safety should not become a means of routinely watching employees or assessing their everyday performance without a separate, justified and transparent purpose.
Employees should have a clear way to raise concerns about inappropriate recording, access or disclosure.
Properly managed footage may also protect employees when an incident is disputed.
Managers should regularly review whether the system is meeting its intended purpose and whether staff understand the rules.
Employees should be confident using their camera before they encounter a difficult or threatening situation.
A camera can help record what happens, but it cannot physically protect someone from violence.
Personal safety, communication, risk assessment and appropriate withdrawal procedures must remain the priority.
Before starting work:
Do not assume a device is functioning simply because it appears to be switched on.
The same daily-check discipline for other devices is set out in Preparing staff to use lone worker devices.
Wear the camera in the position specified by the manufacturer and the organisation's procedures.
Understand that the camera may not capture everything the employee sees or hears.
Clothing, body movements, lighting, background noise and the camera's field of view may affect the recording.
Do not change position or move towards an aggressive person simply to obtain better footage.
Maintain a safe distance from someone whose behaviour is becoming threatening.
Avoid unnecessarily entering the person's personal space.
Keep a clear route to an exit wherever possible.
Do not allow yourself to become trapped in a room, corridor, doorway or confined area.
If the person moves closer, reassess the situation and create distance where it is safe to do so.
There is no single distance that guarantees safety. The appropriate distance depends on the person's behaviour, the surroundings, available exits and other risks.
Recording must never take priority over personal safety.
Where the organisation's policy permits recording, activate the camera at the earliest appropriate opportunity.
Do not wait for physical violence if the circumstances already justify recording.
Where safe and practicable, inform the person that recording is beginning.
If an immediate safety risk makes an announcement impracticable, follow the organisation's documented procedure.
Do not delay necessary safety action merely to activate the camera.
Do not deliberately move closer to someone, point the camera into their face or use the equipment as a means of confrontation.
Avoid comments suggesting recording is intended to embarrass, punish or threaten the person.
Continue using calm communication, appropriate boundaries and de-escalation techniques.
Some people may become uncomfortable or angry when a camera is activated.
An objection does not automatically mean recording must stop, nor does it automatically justify continuing.
Follow the organisation's approved recording purpose and policy.
Explain the situation briefly where safe.
Avoid prolonged arguments about the legal position.
If the person's behaviour escalates, reassess the risk, create distance, seek assistance or withdraw.
Stop recording when the approved purpose has ended, unless another lawful reason for continuing applies.
Do not continue recording unrelated conversations simply because the camera is already operating.
Follow the approved procedure for preserving footage.
Employees must not independently delete a recording because someone objects or because it may reflect poorly on them.
Some body-worn cameras have a pre-event recording function, sometimes called pre-recording or a rolling buffer.
When this feature is enabled, the camera temporarily retains a short period of footage before the employee activates recording.
For example, a device configured with a ten-second pre-event buffer may save the ten seconds immediately before the record button is pressed, as well as the subsequent recording.
Consider a civil enforcement officer who has issued a penalty notice and is walking away. A motorist approaches from behind and grabs the officer before they have time to activate the camera.
If the camera has been correctly configured and the pre-event recording function is operating, activating the camera immediately afterwards may preserve footage showing the approach and physical assault.
This can provide important evidence of an incident that began before the employee was able to react.
However, staff must understand that:
Employees should not delay withdrawing from danger simply to activate recording.
The organisation should identify who is responsible for equipment, training, privacy information, recording procedures, storage, access, retention, disclosure and incident review.
Managers must know how faults are reported, how recordings are secured and who can authorise access.
Body-worn cameras must only be used for authorised work purposes.
Employees must not use cameras to settle personal disagreements, secretly monitor colleagues or record unrelated activities.
Footage must be handled through the organisation's approved systems.
Employees must not:
Unauthorised access or sharing may create serious privacy, safeguarding, employment and legal concerns.
Cameras may capture confidential conversations, documents, computer screens, medical information or other sensitive details.
Employees should remain aware of what may be recorded and follow any restrictions in their organisation's policy.
Where a conversation involves sensitive information, consider whether recording remains appropriate.
Body-worn cameras may also capture employees' names, identification badges, uniforms, vehicles and other identifying information.
Employers should consider whether displaying full names or other personal details is necessary for particular roles.
In some circumstances, a first name and dedicated public-facing staff reference may provide an appropriate balance between accountability and personal safety.
This is a risk-based option, not a universal legal requirement.
The Online Targeting and Harassment guide explains how employers can review name badges, email addresses, signatures and other information that may unnecessarily expose employees.
Recording does not remove the need for respectful communication, professional boundaries or appropriate behaviour.
Employees should continue to explain decisions clearly, avoid unnecessary confrontation and recognise when a situation is becoming unsafe.
The purpose of the camera is to support an approved recording arrangement, not to replace professional judgement.
Employees should be able to explain the use of a body-worn camera calmly and professionally.
Where it is safe and appropriate, a verbal announcement should be brief, clear and consistent with the organisation's policy.
Staff should practise suitable wording before they encounter a difficult situation.
An announcement should explain that recording is taking place and, where appropriate, why.
Employees must accurately describe the recording functions being used.
Example:
I am switching on my body-worn camera because of the behaviour taking place. It will record our interaction.
Where appropriate, add:
The recording will be managed in accordance with our organisation's policy.
My body-worn camera is now recording video and sound.
Employees must describe what their equipment is actually recording.
Do not say that audio is being captured if the device is recording video only.
I understand you are unhappy about being recorded. I can explain why we use these cameras and where you can find our recording policy.
An objection does not automatically mean recording must stop.
The employee must follow the organisation's approved recording purpose, lawful procedures and any applicable restrictions.
Avoid getting drawn into an argument about the law.
I want to deal with your concern, but I cannot continue while I am being threatened. I am going to step away.
Where there is an immediate risk, employees should follow their personal safety procedures rather than delay action to deliver a particular script.
The incident has now ended, and I am stopping the recording.
Employees should stop recording in accordance with their organisation's procedures when the approved purpose has ended.
Avoid statements that are confrontational, misleading or legally inaccurate, including:
Employees should not make absolute statements about retention, disclosure or people's legal rights. These matters are governed by the organisation's recording policy and applicable data protection law.
Informing someone that recording is taking place does not necessarily mean asking for their consent.
The organisation must establish an appropriate lawful basis before operating the camera system.
Employees should not promise that footage will automatically be used in court or that a particular person will receive a copy.
Where announcing the recording would create an immediate safety risk, follow the approved organisational procedure.
A missed announcement during an immediate threat does not automatically turn an otherwise overt recording system into covert surveillance.
Body-worn camera footage must be stored securely and accessed only by authorised people.
Recordings may contain identifiable individuals, sensitive information or evidence relevant to an incident.
The organisation must establish suitable arrangements for transferring, storing, accessing, retaining, disclosing and deleting footage.
Employees should understand their responsibilities but should not be expected to manage legal requests independently.
Use approved equipment and secure systems to transfer and store recordings.
Appropriate safeguards may include:
Recordings must not be transferred to personal email accounts, private cloud storage or unauthorised messaging services.
There is no single retention period appropriate for every organisation.
Footage should be kept only for as long as necessary for its lawful purpose, subject to applicable legal requirements.
Routine recordings may have a different retention period from footage relevant to a complaint, incident, safeguarding concern, investigation or legal claim.
The organisation should document its retention arrangements and explain when recordings must be preserved for longer.
Preservation decisions should be reviewed, and footage should be deleted securely when there is no longer a lawful reason to retain it.
Do not copy the Department for Work and Pensions 30-day example, or any other sector policy, as a universal rule.
People may have legal rights to access personal information about themselves.
Requests must be handled under the applicable law and within the relevant time limits.
Footage may contain information about other people, so disclosure may require appropriate redaction or consideration of a lawful exemption.
Employees should refer requests to the person or team responsible for information governance rather than making their own disclosure decisions.
A subject access search needs to be reasonable and proportionate. Do not answer a subject access request by handing over an unredacted clip of other people.
Footage must only be shared for an appropriate lawful purpose.
Organisations should record:
Requests from police, regulators, solicitors or other authorities should be handled through approved organisational procedures.
Provide a clear way for individuals to raise concerns about recording, access, retention or disclosure.
The organisation must follow the applicable statutory complaint requirements and relevant time limits.
People do not automatically lose their data protection rights because an incident has been recorded.
Since 19 June 2026, section 164A of the Data Protection Act 2018 also requires you to make it easy to complain about data protection, acknowledge a complaint within 30 days and respond without undue delay.
When an incident occurs, the immediate priority is the safety and welfare of everyone involved.
Follow emergency procedures, obtain assistance and arrange medical support where necessary.
Do not remain in a dangerous situation or delay urgent action simply to obtain a recording.
Once the situation is safe, follow the organisation's procedures for protecting the footage and accurately reporting what happened.
A body-worn camera does not necessarily record everything an employee sees or hears.
The recording may miss events happening behind the employee or outside the camera's field of view.
Clothing, rapid movement, poor lighting or background noise may affect the quality of the recording.
A recording should therefore be considered alongside other relevant evidence, including incident reports, witness accounts and information about the circumstances.
Transfer and secure the footage using the organisation's approved procedures.
Employees must not independently edit, trim, enhance, rename or delete original recordings.
Do not share footage through personal accounts or private messaging applications.
Preserve the original file and relevant associated information where required.
Employees should complete a factual incident report as soon as reasonably practicable.
Record:
Where appropriate, obtain the employee's initial account before they review the footage.
This helps distinguish their own recollection from what they later observe on the recording.
Follow specialist investigation requirements where these apply.
In most cases, staff should give their own factual account before viewing the footage. If viewing is later authorised, limit it, log who authorised it, and say in any later account that footage was viewed.
Specialist police guidance may require a victim or witness to review a body-worn recording of their own first account before a further interview. That is not permission for an employer to let all staff freely review an incident. For a possible crime or regulatory case, contact the investigating authority early and follow its directions.
Record the relevant camera and file references, dates, times, uploads, access, transfers and authorised copies.
Preserve associated metadata where required.
Organisations should be able to explain how footage was obtained, stored, accessed and disclosed.
Where recordings may be used in criminal, civil, regulatory or disciplinary proceedings, follow the relevant evidence-handling requirements.
Appropriate specialist advice may be needed.
The Crown Prosecution Service opens in a new tab states that video evidence must be shown to be the original or an authentic copy, and not tampered with. Identify the file with a unique evidence or asset reference. Keep the native original. Never overwrite the source. Write down any clipping, conversion, enhancement, muting or redaction. Hash values can support integrity. They do not replace witness and continuity evidence. Use a secure transfer and follow police, prosecutor, court, regulator or legal instructions.
Once immediate safety and welfare needs have been addressed:
Managers should check the employee's immediate welfare and consider whether further support is needed.
This may include medical assistance, time away from the situation, an appropriate debrief, occupational health support or other arrangements.
The organisation should review whether the incident identifies wider problems with staffing, risk assessment, procedures or equipment.
Before purchasing body-worn cameras, employers should be clear about what they need the equipment to do and how they will manage the recordings.
The cheapest camera or the most impressive product demonstration may not provide the most appropriate system.
Consider the working environment, staff safety, privacy, information security, operational requirements and ongoing costs.
Ask suppliers to demonstrate:
When comparing body-worn cameras, employers should establish whether the equipment supports pre-event recording.
Ask suppliers:
The organisation must assess and document the privacy implications of any pre-event recording function.
The presence of a rolling buffer does not justify unrestricted or continuous recording.
Where a camera stores pre-event footage, employers must explain how the function operates, when it may be used and how recordings are protected.
A controlled pilot can help identify equipment problems and weaknesses in procedures.
Consider whether cameras:
Involve relevant operational staff, health and safety personnel and information governance specialists in the assessment.
Facial recognition, biometric identification and other advanced surveillance features may create additional legal and privacy risks.
They should not be assumed to be covered by an ordinary body-worn camera assessment.
Separate specialist assessment may be required.
Safety Solutions Training Ltd does not sell or endorse particular body-worn camera products.
Our guidance concerns the safe and responsible use of equipment as part of appropriate workplace safety arrangements.
Employees should not be expected to learn how to use a body-worn camera during an actual confrontation.
Before being issued with equipment, they should receive practical instruction and demonstrate that they can use it confidently and correctly.
Training should explain the organisation's recording procedures alongside the personal safety responsibilities that continue to apply when cameras are worn.
Employees should understand:
Where cameras have a pre-event recording function, employees should receive practical instruction on how it works.
Training should include a controlled demonstration in which an incident begins before the employee presses the record button.
Staff should then review the authorised training footage to understand what was captured and whether audio was included.
Employees should know:
Managers should ensure that the function is included in equipment checks and refresher instruction where appropriate.
Employees should have opportunities to practise realistic situations in a controlled environment.
Examples include:
A resident becomes angry during a home visit and begins making threats.
The officer must recognise the developing risk, decide whether recording is justified, explain activation where appropriate, maintain a safe distance and know when to withdraw.
A visitor becomes increasingly abusive.
The employee must follow the camera policy, communicate calmly and request assistance rather than moving closer to obtain footage.
The employee explains the recording arrangements without becoming drawn into an argument.
They must also consider whether continued recording remains justified.
The employee recognises that recording may capture sensitive information and follows the organisation's restrictions or alternative procedures.
These exercises should reinforce that recording never takes priority over personal safety.
Managers should periodically check that employees remain familiar with their equipment and understand the recording rules.
Refresher instruction may be needed when equipment, policies, job roles or identified risks change.
Equipment faults, failed recordings, accidental activations and feedback from employees can provide useful information about further training needs.
Staff should feel confident reporting mistakes or difficulties so that organisations can improve their procedures.
Our Conflict Management and Lone Worker Personal Safety training helps employees recognise warning signs, communicate effectively, maintain professional boundaries, assess developing risks and know when to withdraw.
Where relevant, courses can include practical discussion of the client's existing body-worn camera procedures, recording decisions and incident reporting requirements.
Training should reflect the organisation's approved policies and actual working environment.
Our training does not replace the need for appropriate legal advice, data protection assessments, equipment-specific instruction or properly managed recording systems.
Official sources used for this page
These sources establish general principles. Individual employers must implement arrangements appropriate to their own risks, lawful recording purposes and operational requirements.
Published 28 July 2026. Source check 30 August 2026. Practical-use guidance reviewed 6 November 2026 against Information Commissioner's Office body-worn video guidance, Health and Safety Executive workplace violence guidance and published public-sector body-worn camera procedures. Legislation reviewed on 31 October 2026 against the UK General Data Protection Regulation and the Data Protection Act 2018 as amended by the Data (Use and Access) Act 2025, the Protection of Freedoms Act 2012 and the Equality Act 2010 on legislation.gov.uk, with Information Commissioner's Office, Crown Prosecution Service and GOV.UK Surveillance Camera Code guidance. Next review 1 January 2027, or sooner if Information Commissioner's Office, data-protection, evidence or sector rules change. Not legal advice.
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