CCTV monitoring in food factories can go a long way to supporting industry regulations, but there are some serious limitations to consider, according a legal expert.

The main benefit of CCTV is to retrospectively check incidents, which could have proved useful during the Food Standards Agency’s (FSA) investigations into 2 Sisters and Russell Hume recently.

However, DWF Law partner on global regulatory compliance and investigations Dominic Watkins argues that establishing a CCTV system in every meat cutting plant would be expensive and time-consuming to implement and monitor.

“It requires someone to be doing that remote viewing and requires cameras to be in the right places,”​ Watkins told Food Manufacture. “If you are using it for a form of surveillance, you need to inform your staff that you are doing it.​

“If someone is doing something they are not supposed to be doing, there is a pretty good chance that they know the CCTV is there and there is a good chance they won’t be doing it on the CCTV.” ​

Changing staff practices

Instead of using CCTV as the definitive solution to malpractice, Watkins argued that food processors should look to include the staff in the surveillance process, allowing them to monitor and manage their own actions, while instilling a culture of good habits.

“It has obvious substantial limitations and it is not the one thing that is going to solve all these problems,” Watkins said. “You can avoid it with culture and getting the staff to behave in a particular way and, in general, the sector does pretty well at that.” ​

2 Sisters currently uses CCTV in some of its abattoirs, but the recent investigation by the House of Commons’ Environment, Food and Rural Affairs select committee found that more extensive coverage would have proven useful. In response, 2 Sisters founder Ranjit Singh Boparan promised to expand the use of CCTV to cutting and processing plants.  The company pledged 100% coverage.

“We already lead the sector with this. All our abattoirs already have CCTV, and the majority of our cutting plants also,” said 2 Sisters in a statement. “I think most colleagues appreciate the system, as CCTV is such a fact of life nowadays, and it brings confidence and reassurance for both colleague and employer.”​

Legal aspect of CCTV

Implementing CCTV would have implications for several aspects of the Data Protection Act (DPA), the Information Commissioners Office (ICO) has said.

“The Act does not prevent an employer from monitoring workers, but such monitoring must be done in a way which complies with it,” the ICO said in its code of practice. “We recommend that organisations carry out a privacy impact assessment to ensure these criteria are met.”

Privacy impact assessments look at privacy in a wider context, focusing on the impact on privacy rights. According to the first Guiding Principle of the Protection of Freedoms Act, CCTV should be only be used to satisfy a particular need and so it must be justified based on reliable evidence.

CCTV in abattoirs

In August 2017, food minister Michael Gove announced that all abattoirs in the UK must implement mandatory CCTV to ensure compliance and to protect animals from abuse.

Animal Aid director Isobel Hutchinson told Food Processing Technology last year that illegal abuse of animals was recorded in 93% of UK slaughterhouses investigated.

“The advantage with mandatory CCTV would be that people would know they were being watched and it would hopefully have a deterrent effect,” she said.

Animal Aid estimated CCTV would cost £150,000-£370,000 annually for all English slaughterhouses, but these costs could be absorbed by the industry and the consumer, rather than through taxes.