Continuous recording

A. If your employer wants to introduce continuous recording, you should be consulted properly. The most important source material to help you is probably the Information Commissioner’s CCTV Code of Practice, updated in October 2014, and available on the Information Commissioner’s Office website.

The Code does not refer specifically to audio recording in HGV cabs, but it does state that “the use of audio recording, particularly where it is continuous, will in most situations be considered more privacy intrusive than purely visual recording and will therefore require much greater justification” [than the equivalent CCTV camera without sound].

Continuous recording is a serious privacy intrusion, as drivers spend many hours in their cab, so it needs persuasive justification. Your employer should produce proper evidence of a pressing need (such as road safety) for which continuous recording can be shown to be a proportionate response.

To comply with the Code, employers should conduct a proper privacy impact assessment; share their results with workers; consult fully, listening to workers’ concerns; consider alternative solutions; and make reasonable modifications.

https://ico.org.uk/media/for-organisations/documents/1542/cctv-code-of-practice.pdf