Welcome To Our CCTV And Recording Policy

For your safety and ours, all our vehicles are fitted with internal and external video and audio recording equipment. This is considered best practice in the professional driving industry. Both forward and rear facing cameras are there to protect our customers and our drivers, and will be recording the entire trip, except in limited situations outlined in other policy documents.

Audio recording is disabled by default. It may be activated where reasonably necessary to address a safety concern, threat, dispute or suspected misconduct. Audio recording will cease when no longer required.

Recordings are kept for 28 to 35 days unless an incident is reported by the driver or passenger. In such cases, footage will be retained until all matters are resolved plus up to 1 year if it is deemed appropriate. Relevant recordings may be disclosed to the police, licensing authorities, courts or other authorised bodies where required or permitted by law. Any disclosure will be assessed and handled in accordance with applicable data protection requirements.

Any recording or other data related to a complaint, criminality, or safeguarding concerns will be kept for an appropriate period in line with applicable data protection legislation. These are reviewed periodically to ensure continued relevance.

All recordings are securely stored and accessible only to our office team. If you need access to footage from your journey, as per your statutory rights, it can be provided upon request.

The company may, at its discretion, utilize the forward facing videos from specific routes for the purpose of training and improvement, and these fall outside of the standard deletion windows. We keep these for up to 3 months. None of these videos are to have audio, or to show either the passenger, their pick up, or drop off location. This is to protect the privacy of our customers and their details, while having real data on how the vehicle is being driven, and how it can be made better for our customers. If these recordings are deemed relevant or useful to keep long term, they will be effectively anonymised, leaving just the training/educational material.

Wright Travel processes CCTV recordings for safety, security, incident investigation and the establishment, exercise or defence of legal claims, training, and quality control, in accordance with our GDPR Policy and applicable data protection legislation.

For our GDPR compliance policy, click here.

CCTV Data Protection Impact Assessment

Our Approach

Wright Travel Ltd operates CCTV systems to help protect passengers, drivers and other road users.

We recognise that CCTV records personal information and can affect individual privacy. We therefore assess the necessity, proportionality and security of our recording arrangements in accordance with UK data protection legislation.

This section provides a public summary of our assessment.

Why CCTV Is Necessary

CCTV serves four principal purposes:

1. Passenger and Driver Protection

Recording helps deter inappropriate behaviour and provides evidence when an incident occurs.

2. Fair Investigation of Complaints

CCTV can protect both customers and drivers by providing objective evidence.

Where an allegation cannot otherwise be substantiated, video evidence may help establish what actually happened, protecting innocent parties and supporting legitimate complaints.

3. Road Safety and Legal Protection

Forward-facing recordings may provide evidence concerning collisions, dangerous driving and other incidents involving road users.

4. Training and Improvement

Selected forward-facing recordings may be used to review driving techniques, route decisions and opportunities to improve passenger comfort and safety.

Why We Consider Our Recording Proportionate

We have considered alternatives to our existing recording arrangements.

A forward-facing camera cannot record events inside the passenger compartment.

An interior camera can provide evidence of events involving passengers and drivers, but does not generally establish the content of conversations.

Audio recording is more intrusive. We therefore disable it by default and permit activation only where reasonably necessary to address safety concerns, threats, disputes or suspected misconduct.

We consider that this approach balances the benefits of independent evidence against passengers’ reasonable expectations of privacy.

Storage and Access

Recordings are initially stored locally within the vehicle before being transferred to restricted-access company storage.

Wright Travel does not routinely transfer its CCTV recordings to third-party cloud storage services.

Access to recordings is restricted to the company director.

We recognise that removable recording media can present risks of unauthorised access, loss or theft. Our security arrangements are assessed with these risks in mind, including the need for physical security, restricted access and appropriate technical protection.

Retention and Deletion

Ordinary recordings are retained for 28–35 days through our weekly recording-management cycle.

This variation reflects the age of recordings when the relevant weekly deletion takes place.

Recordings associated with incidents, complaints, safeguarding concerns or legal proceedings may be retained for longer where reasonably necessary.

Selected forward-facing training recordings may be retained for up to three months. Material retained for longer-term educational purposes will be effectively anonymised.

Privacy Risks

We recognise that CCTV presents several risks to individuals:

• Personal information could be accessed by unauthorised persons.
• Recordings could be lost, stolen or disclosed inappropriately.
• Audio recording could capture private conversations.
• Recordings could be retained beyond the period reasonably necessary.
• CCTV could intrude unnecessarily on children, vulnerable passengers or private activities.

We seek to reduce these risks through restricted access, limited retention, appropriate physical and technical safeguards, restrictions on audio recording and additional privacy arrangements where appropriate.

Data Protection Rights

Passengers and other identifiable individuals retain their applicable rights under the UK GDPR and Data Protection Act 2018.

These include rights concerning access to personal information and, in applicable circumstances, its correction or deletion.

Requests are considered in accordance with the relevant legal requirements.

Ongoing Assessment

Our assessment considers the likelihood and potential severity of privacy risks, the measures available to reduce those risks, and whether remaining risks are justified by the benefits of recording.

Wright Travel reviews its CCTV arrangements when there are significant changes to recording equipment, storage, operating procedures or relevant legal requirements.

Our objective is to maintain an appropriate balance between safety, accountability and the privacy of the people who use our services.