Resources and learning

Two girls sit behind a bench, smiling at the camera. They are between 12 and 14. They both wear a school uniform of white shirt and school tie with a blue tartan skirt. The girl on the left has dark hair pulled back into a ponytail. The girl on the right has a fringe and shoulder-length pigtails. She also has dark hair. Schools sometimes want to know if they can install CCTV in children and young people’s bathrooms to deter negative behaviour such as vaping and bullying.

Bathrooms are highly sensitive zones for privacy and there’s some clear points that schools need to consider first.

Schools need to be open with their communities about using CCTV and have clear signage and notices about it.
They need to take care to focus cameras away from intimate activity (i.e., toileting and changing).
Schools also need to be sure they’re not using audio to pick up conversations without additional privacy assessments done first.

Considerations for Boards of Trustees and principals

Remember that everyone, regardless of their age, has privacy rights.
Be open with your school community, including staff and students, about what information you are collecting, from where, and why.
Only collect what is needed for the lawful purpose it’s going to be used for. That lawful purpose must relate to the functions or activities of that school.
Keep the information safe by understanding who will be viewing any footage captured and limit that access to only those who need to see it.
Know how long you’ll need to keep information for and when it will be deleted.
Boards of Trustees and principals must ensure there are safeguards in place that are reasonable in the circumstances. These will make sure that those rules are followed, and to provide assurance to individuals that the measures will prevent the loss, misuse, or disclosure of personal information collected by the CCTV.

We recommend that that schools looking to install CCTV do a privacy impact assessment (PIA) for their school’s situation. If they already have a PIA then they need to update it to extend CCTV to sensitive areas like toilets and changing areas.

Completing a PIA helps people identify and assess the privacy risks of data collection. It will also propose ways to mitigate or minimise those risks, including considering less privacy intrusive way of achieving what schools want to do.

Read other privacy information for Boards of Trustees.