CCTV Monitoring Procedure

Position Statement:

BPO Manufacturing has committed to ensuring that there is sufficient CCTV in place on site for the monitoring of personnel, visitors, contractors and to maintain site security.

Objectives:

To ensure effective monitoring of personnel’s, visitors’ and contractors’ on site, for the Food Safety Culture, Employee Wellbeing, Safety and Good Manufacturing Practices of the business and all team members.

Scope:

BPO Division: Primary, Value Added, Bakery This procedure applies to all CCTV monitoring equipment on site, all employees, visitors and contractors.

Responsibility Area R
Who is Responsible?		 A
Who is Accountable?		 C
Who should be consulted?		 I
Who should be informed?
Communicate, implement and monitor this procedure Site Director / General Manager / Human Resources Operations Director Technical/EHS Technical/EHS
To ensure this procedure is adhered to at all times GMP Auditors / CCTV Monitors / FSQC Co-ordinators Head of Technical / Technical Manager / Human Resources Manager Site Director / General Manager / Union (if applicable) Site Director / General Manager

Procedure:

M1. CCTV System

  1. The CCTV system must be operational and images are capable of being monitored twenty-four hours a day throughout the year. All CCTV cameras are configured to record images only: any sound recording facilities will be switched off or disabled.
  2. All employees, visitors and contractors must be made aware of the presence of the CCTV system by appropriate signage which must be clearly visible, readable and sets out the purposes for processing the CCTV images and identifies BPO as the data controller responsible for processing those images.
  3. The CCTV equipment must be maintained and tested in accordance with a regular schedule. A competent, designated personnel on site will be responsible for testing the quality of images to ensure that recorded images and prints as well as live images are clear and fit for purpose.
  4. Images captured by cameras will be recorded on equipment located securely in a self-contained room within the site buildings. Access must be restricted and individually assigned and recorded on each entry/exit.
  5. Recorded media must be stored for a minimum of 6 months or until capacity is reached, whichever is the shorter period. After 30 days it will reduce to 1 frames per second, excluding all lairage/welfare cameras which remain at 180 days.

M2. CCTV Privacy Impact Assessment

  1. A CCTV Privacy Impact Assessment (PIA) must be carried out at each site prior to introduction of CCTV operations on site using ‘BPO UKP CCTV Privacy Impact Assessment Form (PIA)’ and in accordance with the data protection principles.
  2. CCTV PIA Form must be regularly reviewed, minimum annually and after significant changes to site buildings and operations, to identify and reduce privacy risks and ensure that CCTV use remains justified.
  3. Authorisation to proceed must be signed off and recorded on the PIA form prior to launch of CCTV monitoring operations on site.

M3. CCTV Monitoring Room

  1. Access to view CCTV recordings must be restricted and the monitoring system must only be used for the purpose it was intended for.
  2. Handling of images and information within the CCTV Monitoring Room must be carried out in accordance with these procedures and the Group CCTV & Surveillance Policy.
  3. Where possible, CCTV Monitoring Room shall be located close to the factory to enable quick access when necessary.
  4. No mobile phones are permitted while monitoring.

M4. CCTV Monitoring Personnel

  1. One CCTV GMP Auditor must be present on each shift during factory operational hours (production only). The auditor will report directly to Head of Technical / Head of Human Resources or Technical Manager /(Human Resources Manager in the absence of a Head of Technical.
  2. The Auditor must be fully trained on all relevant site procedures, including the internal audit procedure, GMP and relevant bulletins prior to commencement.
  3. Suitability of a candidate for the role of GMP Auditor must be thoroughly assessed to ensure that they:
    1. Have good attention to detail
    2. Have excellent understanding of the site GMP rules and be able to explain the reason behind these rules to operators, supervisors and area managers.
    3. Be able to speak and write very good English.
    4. Be confident in engaging teams at all levels and be proactive in preventing significant GMP breaches.

M5. CCTV Monitoring Programme

  1. The monitoring routine will consist of the following:
    1. One hour at a time monitoring GMP on CCTV camera recordings on screen (Cameras in production and packing areas).
    2. Another hour in the factory, physically verifying conformance against procedures and site GMP rules and engaging with team leaders and area managers; coaching and supporting staff with learnings and driving food safety culture and standards.
    3. The above shall result in 50% of the auditor’s time used in monitoring GMP via CCTV and the other 50% used in following up findings/investigating and challenging practices on the factory floor. Or if resource allows, it can be one person watching the camera’s and one in the factory, physically verifying conformance against procedures and site GMP rules and engaging with team leaders and area managers.

CCTV and GMP Verification Daily Shift Schedule (standard morning shift example)

Monitoring Activity 6:00am 7:00am 8:00am 9:00am 10:00am 11:00am 12:00am 13:00pm
CCTV Recording Monitoring A A A A
Physical GMP Factory Verification A A A A
  1. Monitoring Staff present
  2. Breaks will be taken in line with company policy and compliance with Health and Safety Standards (DSE).
  3. Appropriate cover of monitoring activities above must be provided during holidays and other absences, as well as during overtime and early starts. A member of the factory QA team shall be trained to provide cover when necessary.

M6. CCTV Monitoring Records and Corrective Actions

  1. All findings and time spent monitoring each camera must be logged. Communication of issues to the factory floor and/or Technical Manager/Head of Technical shall be in real time and actions taken must also be recorded.
  2. GMP Auditors must challenge, coach/mentor and support (offer advice) immediately after bad practices are observed.
  3. Records of bad practices observed and actions taken shall be transferred onto a database accessible only to a predefined list of colleagues. These must enable easy extraction of common themes/findings for training purposes.
  4. Implementation of any new ways of working or improvement actions must also be monitored and recorded.

M7. Findings and Escalation

  1. Non-conforming practices shall be categorised as either minor, major or critical.

    Minor Non Conformances – isolated instances of GMP failures e.g. incorrect hair coverage, dirty or damaged overall, excess make-up etc. Failure to make corrective action following initial report may result in disciplinary action in accordance with Company’s disciplinary procedure.

    Major Non Conformances – numerous instances of the same GMP failures, significant compromise to process or product integrity such as temperature abuse (stock left out of chillers for more than 30 minutes), an isolated tray without a label, evidence of product contamination which gets detected and resolved, etc. Failure to follow procedure resulting in major non conformances may result in disciplinary action in accordance with Company’s disciplinary procedure.

    Critical Non Conformances – Evidence of product contamination which goes undetected, food handlers picking meat off the floor, floor meat put on production line, poor line clearance and line gaps, label changes during a production run, two kill dates at the same work station and other breaches to bulletin 15 requirements. Critical Non Conformances may be considered gross misconduct and will be dealt with in accordance with the Company’s disciplinary procedure.

    NCN Category Themes (not limited to):
    Meat on Floor
    Culture/general bad practice
    Use of Mobile Phones
    Personal Hygiene – washing of hands
    Process Hygiene
    Equipment Handling
    PPE
    Labelling & Traceability
    Non-Conforming Product
    Product Handling
    CCP
    Weight Control
    Temperature Control
    H&S Breach

    • (If >10 minors in any sub-category then it becomes a Major. Example: 11 people not washing hands correctly would become 1 major).
  2. All minor non-conformances shall be reported to the area leader and resolved immediately. Major non-conformances shall also be reported to the Technical Manager or Head of Technical and the Site Director or General Manager and resolved immediately. A member of the divisional Senior Management Team shall be informed of any critical non-conformances raised.
  3. A weekly score of findings shall be generated as follows and communicated through the weekly technical dashboard:

    • <10 Minor Non Conformances per week – Green
    • ≥10 Minor Non Conformances or 1 Major Non Conformances per week – Amber
    • >1 Major Non Conformance or 1 Critical Non Conformance – Red.

M9. Guidelines for Implementing CCTV Monitoring

  1. For new or amended use of CCTV please complete the BPO UKP CCTV Privacy Impact Assessment Form (PIA)’ in accordance with the data protection principles.
  2. Map the current coverage of CCTV (Internal & External) and log where the blind spots are and whether all key processes and CCP areas are covered by the current camera’s. Also include coverage for areas where Induction Training is completed. For areas identified as not having sufficient coverage or that don’t have appropriate camera’s (i.e. Atex rated for areas using powders) please add these requirements to the sites capital project log for resolution.
  3. Survey the quality and direction of the images from the current camera’s and create a log of which camera ID’s refers to which areas of site coverage. Please ensure that Whistleblower posters are not positioned within areas that are covered by CCTV that could identify colleagues.
  4. Create a room for the monitoring of CCTV which allows privacy and adequate space for the required number of monitor screens. Also provide lockable areas for holding sensitive documentation.
  5. Set up an effective method of communication between the CCTV Monitoring room and the key contacts within the factory i.e. 2 Way radios.
  6. All staff that will monitor CCTV must be suitably trained and have signed an appropriate NDA prior to monitoring CCTV.
  7. Ensure that signage around the site reflects the current use and purpose of CCTV and that employees are made aware of the use of the CCTV data.

Also please refer to the CCTV section in A to Z in the Book of Everything.