Covert monitoring

Housing 21 will never engage in covert monitoring or surveillance (that is, where individuals are unaware that the monitoring or surveillance is taking place) unless, in highly exceptional circumstances, there are reasonable grounds to suspect that criminal activity or extremely serious malpractice is taking place and, after suitable consideration, having undertaken a DPIA, we reasonably believe there is no less intrusive way to tackle the issue. 

In the rare event that covert monitoring is justified, it will only be carried out with the express authorisation of the Deputy Chief Executive or where they are not available, an Executive Director. The decision to carry out covert monitoring will be fully documented and will set out how the decision to use covert means was reached and by whom. The risk of intrusion on innocent workers will always be a primary consideration in reaching any such decision.  

Only limited restricted authorised individuals will be involved in covert monitoring.  This requires sign off from an Executive Director, the Deputy Chief Executive, (currently the SIRO) and liaison with the Data Protection Officer (DPO).  Please refer to the CCTV Procedure for full details.    

Covert monitoring will only be carried out for a limited and reasonable period consistent with the objectives of making the recording and will only relate to the specific suspected illegal or unauthorised activity.