Vehicle Dashcam & Driver Monitoring

Important Information for Drivers

Our company vehicles are fitted with inward-facing and outward-facing dashcams.

The cameras are used to help protect our drivers, passengers, vehicles and other road users, as well as to provide reliable evidence where an accident, incident or other event occurs.

We understand that cameras inside a vehicle can feel intrusive. We therefore aim to operate the system fairly, proportionately and transparently, in accordance with applicable UK data protection legislation and our company policies.

 

This page explains:
  • Why the cameras are being used

  • What the cameras record

  • When recording takes place

  • How footage is stored and used

  • Who may access footage

  • How long footage is retained

  • When footage may be shared

  • How dashcam footage may be used in investigations

  • Your rights regarding your personal information

  • The relevant UK laws and guidance


1. Why Do We Use Dashcams?

The cameras are installed for legitimate business, safety and security purposes.

These purposes include:

  • Protecting the safety of drivers and passengers

  • Improving road safety

  • Providing evidence following road traffic collisions

  • Investigating accidents and other incidents

  • Protecting company vehicles, equipment and assets

  • Protecting drivers against false, disputed or unsubstantiated allegations

  • Supporting insurance claims and investigations

  • Providing evidence to the police or other relevant authorities where appropriate

  • Investigating suspected criminal activity

  • Investigating serious safety concerns

  • Investigating potential breaches of company policies or procedures

  • Identifying opportunities to improve driver and road safety

The cameras are not installed simply to watch or monitor drivers.

However, where footage identifies serious unsafe driving, misconduct, criminal activity or another legitimate concern, the company may review and use the footage as part of an appropriate investigation.

Any use of footage will be considered in accordance with the company’s policies and applicable data protection requirements.


2. What Cameras Are Installed?

Vehicles are fitted with both outward-facing and inward-facing cameras.

Outward-Facing Camera

The outward-facing camera records the road and surroundings in front of the vehicle.

This may capture:

  • Other vehicles

  • Vehicle registration numbers

  • Pedestrians and cyclists

  • Road signs

  • Road conditions

  • Traffic conditions

  • Road traffic collisions

  • Other events occurring around the vehicle

The purpose of the outward-facing camera is primarily to provide evidence relating to road safety, accidents, incidents, insurance claims, vehicle security and other legitimate business purposes.


Inward-Facing Camera

The inward-facing camera records the interior of the vehicle and may capture the driver and passengers.

This may include:

  • The driver

  • Passengers

  • Driver behaviour

  • Events occurring inside the vehicle

  • Incidents taking place within the vehicle

We recognise that an inward-facing camera is more intrusive than an outward-facing road camera.

For this reason, access to and use of inward-facing footage will be limited to legitimate and proportionate purposes.

The company will not routinely monitor drivers simply for the purpose of watching their day-to-day activities.


3. When Does Recording Take Place?

The cameras operate in accordance with the vehicle’s camera system configuration.

For example:

The cameras automatically begin recording when the vehicle ignition is switched on and continue recording while the vehicle is being operated.

Drivers should assume that the vehicle camera system is operational whenever the vehicle is being used, unless they have been specifically informed otherwise.


4. Is Audio Recorded?

The vehicle cameras are capable of recording audio; however, audio recording is disabled.

The company does not routinely record conversations taking place inside the vehicle.

The Information Commissioner’s Office (ICO) considers audio recording to be particularly intrusive and recommends that it generally be switched off unless there is a specific and justified reason for recording it.


5. Can Drivers Switch Off or Disable the Cameras?

Drivers must not disconnect, cover, obstruct, disable, tamper with or otherwise interfere with the vehicle camera system.

This includes:

  • Covering the camera lens

  • Unplugging the camera

  • Disconnecting power to the system

  • Interfering with camera wiring

  • Attempting to delete recorded footage

  • Attempting to alter or manipulate recorded footage

  • Deliberately positioning objects to prevent the camera from recording

Any technical fault or damage to the camera system should be reported to Fleet@llgnw.co.uk as soon as reasonably practicable.

If there are circumstances in which the inward-facing camera may legitimately be disabled, these will be set out in the company’s vehicle monitoring policy.


6. Private Use of Company Vehicles

Company vehicles are provided for business purposes but can be used for private use before and after work unless specifically stated by the company.

Where a vehicle is permitted to be used privately, the company’s camera system must still be operational and unaltered – the camera is a legal requirement by the Insurance. Without a working telematic system, the vehicle would be classed as uninsured.


7. How Is Dashcam Footage Used?

Routine footage is not routinely viewed by management simply to monitor drivers.

Footage may be accessed where there is a legitimate reason, including:

  • A road traffic collision

  • An accident or incident

  • An insurance claim

  • A complaint or allegation

  • A suspected criminal offence

  • A significant road safety concern

  • Suspected dangerous or seriously unsafe driving

  • A potential serious breach of company policy

  • A vehicle security issue

  • A request from the police or another lawful authority

  • A legal requirement

  • Another legitimate business or safety purpose

Where footage is reviewed, the company will consider whether doing so is necessary, reasonable and proportionate to the circumstances.


8. Can Dashcam Footage Be Used for Disciplinary Purposes?

Yes, where appropriate.

Dashcam footage may identify potential misconduct, unsafe driving, criminal activity or a serious breach of company policy.

Where this occurs, relevant footage may be used as part of an investigation or disciplinary process.

For example, footage may be considered where it provides evidence of:

  • Dangerous or seriously unsafe driving

  • Deliberate or reckless behaviour

  • Use of a mobile phone while driving

  • Failure to wear a seatbelt

  • Driving contrary to company safety procedures

  • Deliberate damage to company property

  • Suspected criminal activity

  • Other serious breaches of company policy

The existence of camera footage does not automatically mean that disciplinary action will be taken.

Any decision will be considered based on the individual circumstances and in accordance with the company’s relevant policies and procedures.


9. How Is Footage Stored?

Dashcam footage is stored using the vehicle camera system and the Samsara Portal.

Access to recorded footage is restricted to authorised individuals who require access for legitimate business, safety, legal, insurance or investigative purposes.

Appropriate technical and organisational measures are used to protect footage against:

  • Unauthorised access

  • Unauthorised disclosure

  • Loss

  • Destruction

  • Alteration

  • Accidental disclosure


10. How Long Is Footage Retained?

Routine footage is automatically overwritten after approximitely 21 days, depending on the vehicle usage, unless it has been identified as being relevant to an accident, incident, investigation, insurance claim, legal matter or another legitimate purpose.

Where footage is required for an ongoing matter, it may be retained for longer than the standard retention period for as long as it is reasonably necessary.

Once footage is no longer required, it will be securely deleted or otherwise disposed of in accordance with the company’s retention procedures.

The company does not retain footage indefinitely.


11. Who Can Access the Footage?

Access to dashcam footage is restricted to authorised personnel.

Depending on the circumstances, this may include:

  • Fleet or Transport personnel

  • Health & Safety personnel

  • Senior management

  • Authorised company personnel

  • Insurance providers and claims handlers

  • Solicitors or other professional advisers

  • Police or other law-enforcement authorities

  • Other relevant parties where there is a legitimate legal or business requirement

Footage will not be shared simply because someone requests it.

Any disclosure will be considered in accordance with applicable data protection legislation, legal requirements and the company’s internal procedures.


12. Can Footage Be Provided to the Police?

Where legally appropriate, the company may provide relevant footage to the police or another law-enforcement authority.

This may occur following:

  • A road traffic collision

  • A suspected criminal offence

  • A request made as part of a lawful investigation

  • Another situation where disclosure is legally justified or required

Drivers must not independently delete, alter or provide company-owned footage unless authorised to do so.


13. What Happens If There Is an Accident?

If an accident or significant incident occurs, relevant camera footage may be preserved before it is automatically overwritten.

The footage may then be reviewed by authorised personnel.

Where appropriate, it may be shared with:

  • The company’s insurer

  • Claims handlers

  • Solicitors

  • The police

  • Other relevant parties

The dashcam system does not replace the company’s normal accident-reporting procedure.

Drivers must continue to report accidents and incidents in accordance with the company’s normal procedures.


14. Driver Responsibilities

All drivers are expected to:

  • Drive safely and responsibly

  • Comply with UK road traffic laws

  • Remain in proper control of the vehicle

  • Follow the company’s driving and vehicle safety policies

  • Report accidents and incidents promptly

  • Report camera faults or damage

  • Cooperate with reasonable investigations

  • Leave the camera system unobstructed

  • Ensure that the camera system is not deliberately interfered with

Drivers must not:

  • Cover the camera

  • Disconnect the camera

  • Unplug the camera

  • Tamper with camera wiring

  • Attempt to delete footage

  • Attempt to alter recorded footage

  • Deliberately obstruct the camera

  • Interfere with the operation of the camera system

  • Use or distribute company camera footage without authorisation


15. UK Road Traffic Law

The dashcam system does not change the legal responsibilities of the driver.

Drivers remain responsible for complying with all applicable UK road traffic laws.

This includes requirements relating to:

  • Safe driving

  • Proper control of the vehicle

  • Speed limits

  • Seatbelts

  • Mobile phone use

  • Drink and drug driving

  • Driver attention

  • Vehicle condition

  • Parking and stopping

  • Other applicable road traffic legislation

Mobile Phones

Drivers must not use a hand-held mobile phone or other prohibited hand-held device while driving, except where a specific legal exemption applies.

Using a hand-held mobile phone while driving can result in:

6 penalty points and a £200 fine.

In certain circumstances, drivers can also face further penalties.

Drivers should ensure that mobile phones are safely positioned and do not require them to hold or operate the device while driving.

For the latest government guidance, please visit:

GOV.UK – Using mobile phones when driving

 


16. UK Data Protection Law

Because the cameras may capture identifiable individuals, including employees, passengers, pedestrians and other road users, the information recorded can constitute personal data.

The company’s use of this information must therefore comply with applicable UK data protection legislation, including the:

  • UK General Data Protection Regulation (UK GDPR)

  • Data Protection Act 2018

  • Other applicable data protection legislation and regulatory requirements

This includes requirements concerning:

  • Lawfulness

  • Fairness

  • Transparency

  • Purpose limitation

  • Data minimisation

  • Accuracy

  • Storage limitation

  • Security

  • Accountability

The company will only use camera footage for legitimate and appropriate purposes.


17. Your Privacy

We recognise that being recorded while working can raise legitimate privacy concerns.

The company will therefore seek to ensure that camera monitoring is:

Necessary – there is a genuine reason for using the system.

Proportionate – the level of monitoring is appropriate for the purpose.

Transparent – drivers are informed about how and why the system operates.

Secure – footage is protected against unauthorised access or disclosure.

Limited – footage is not retained or accessed for longer than necessary.

The company will regularly review its use of vehicle cameras to ensure that the system continues to meet its intended purposes.


18. Your Data Protection Rights

Under UK data protection legislation, you may have rights in relation to your personal information.

Depending on the circumstances, these may include:

  • The right to be informed about how your information is used

  • The right to request access to your personal information

  • The right to request correction of inaccurate information

  • The right to request deletion of personal information in certain circumstances

  • The right to request restriction of processing in certain circumstances

  • The right to object to certain processing

  • Rights relating to automated decision-making and profiling, where applicable

These rights are subject to certain legal exemptions and limitations.


19. Requesting Footage of Yourself

If you believe you appear in recorded footage and wish to request access to your personal data, you can submit a Subject Access Request (SAR).

Please contact Fleet.

When making a request, please provide as much information as possible, including:

  • Your name

  • Vehicle registration or vehicle number

  • Approximate date

  • Approximate time

  • Location

  • Description of the incident or footage requested

Providing this information will help us identify the relevant footage.

Please be aware that footage may also contain images of other individuals. There may therefore be circumstances where footage needs to be reviewed, redacted or withheld before it can be provided.


20. What If I Have Concerns About the Cameras?

If you have concerns about:

  • The operation of the cameras

  • The use of inward-facing monitoring

  • How your personal information is being processed

  • How footage has been accessed or used

  • The retention of footage

  • The sharing of footage

  • A potential breach of privacy

Please contact:

Paul Conning

Email: paul.conning@llgnw.co.uk

Telephone: 0151 352 6600

We will investigate concerns in accordance with our company policies and data protection procedures.


21. Complaints

If you are unhappy with how we have handled your personal information, please contact us in the first instance using the details provided above.

You also have the right to raise a concern with the Information Commissioner’s Office (ICO).

The ICO is the UK’s independent regulator for data protection and information rights.


22. Further Information

Further information about workplace monitoring, vehicle surveillance and data protection can be found on the Information Commissioner’s Office website.

Further information about UK road traffic law and driving requirements can be found on GOV.UK.


Acknowledgement

By using a company vehicle fitted with a dashcam, drivers acknowledge that they have been provided with information explaining the operation and purpose of the vehicle camera system.

Drivers are encouraged to raise any questions or concerns with Fleet@llgnw.co.uk.