The use of audio recording, particularly where it is continuous, will, in most situations, be considered more privacy intrusive than purely visual recording. Its use will therefore require much greater justification.
Audio recording should only be used where:
You have identified a need or issue which can be characterised as a pressing social need and can evidence that this need must be addressed.
1. You have considered other less privacy intrusive methods of addressing the need.
2. Having reviewed the other less privacy intrusive methods, you have concluded that these will not appropriately address the identified issue and the only way to address the issue is through the use of audio recording.
3. You should ensure that at the point of purchase of the audio system all appropriate privacy by design methods have been incorporated into the system. If you have already bought the system, you should look to see if you can incorporate any privacy by design technologies.
4. If you are using audio recording you should make sure that the system you have bought provides a high enough quality of recording to achieve your stated aim.
5. You should make it clear to data subjects that audio recording is taking place, over and above any visual recording which is already occurring. 6. The best way to make sure these requirements are met is to carry out a thorough privacy impact assessment.
