The use of CCTV, audio monitoring and other forms of surveillance in residential childcare settings requires careful consideration. Providers must balance their responsibility to safeguard children with the need to respect children’s privacy, dignity and individual rights.
Ofsted has published specific guidance explaining how inspectors will evaluate the use of surveillance and monitoring across residential childcare services, including children’s homes and supported accommodation.
The guidance was updated in July 2024 to specifically include supported accommodation services.
Which services does the guidance apply to?
The Ofsted guidance applies to:
- Children’s homes
- Supported accommodation
- Residential family centres
- Secure children’s homes
- Residential holiday schemes for disabled children
- Residential accommodation in schools
Surveillance should never be the default
One of the clearest messages within Ofsted’s guidance is that surveillance must not become a default method of monitoring children’s behaviour.
The use of CCTV or other monitoring systems must meet the needs of the individual and be justified at the time.
Providers should be able to explain why surveillance is necessary and why less intrusive safeguarding measures would not be as effective.
Indiscriminate monitoring of groups of children is not considered acceptable.
Importantly, Ofsted states that surveillance and monitoring devices should be used for the protection of children, rather than for the protection or monitoring of staff.
What does this mean for supported accommodation?
Supported accommodation providers should pay particular attention to Regulation 6(2)(c) of the Supported Accommodation (England) Regulations 2023.
Monitoring or surveillance devices may only be used in communal areas and only within the circumstances permitted by the regulations.
Providers should therefore be able to clearly demonstrate the purpose of any CCTV or monitoring system, how its use has been assessed and how the arrangements protect the privacy and rights of young people.
The existence of CCTV within a property does not, by itself, demonstrate that its use is appropriate or proportionate.
Individual risk assessment and care planning
Where surveillance is used to safeguard an individual child, Ofsted expects the reasons and rationale to be clearly recorded within the child’s care plan.
The decision should be based on an individual risk assessment and agreed with the placing authority’s social worker.
Where possible, children, parents and social workers should be involved in decisions and regular reviews regarding whether surveillance remains necessary.
Consent should also be considered, alongside clear information about how a child or parent can raise concerns or make a complaint about the use of surveillance.
Providers should regularly review arrangements rather than allowing surveillance measures to continue indefinitely without challenge.
What will Ofsted inspectors look at?
During an inspection, inspectors may explore:
- The reasons for using surveillance or monitoring
- Whether the arrangements comply with the regulations relevant to the service
- How children’s privacy, dignity and human rights have been considered
- Whether less intrusive safeguarding options were explored
- The quality and impact of the provider’s surveillance policy and procedures
- Whether staff follow the provider’s own policy
- How surveillance information and recordings are managed
- Any safeguarding concerns identified through the use or misuse of surveillance
Where inspectors identify shortfalls, these may be reflected within the inspection report. Ofsted may also consider enforcement action where providers have failed to adequately safeguard children, promote their rights or respect their dignity.
What should your surveillance and monitoring policy include?
As a minimum, Ofsted expects providers to clearly set out:
- The legitimate purpose and aim of each surveillance activity
- How surveillance contributes to children’s safety
- Why surveillance is considered the most appropriate way of achieving the intended safeguarding outcome
- How recordings and data are processed and securely stored
- The measures used to prevent unauthorised access or use
- How frequently surveillance arrangements are reviewed
- How arrangements are agreed with placing authorities, parents, carers and children, where appropriate
- How visitors and other professionals are informed that recording is taking place
Policies should reflect the actual arrangements within the service. Inspectors will expect providers and staff to follow their own procedures in practice.
Review or purchase a Surveillance and Monitoring Policy and Practice Pack
If your service already has a surveillance or CCTV policy, Social Care Skills can review it against current Ofsted guidance and the regulatory requirements relevant to your service. Our policy review support helps identify gaps, unclear procedures and areas where the written policy may not fully reflect your actual practice.
Alternatively, providers can purchase a Surveillance and Monitoring Policy template and Practice Pack from Social Care Skills. Our sector-specific templates provide a structured starting point for children’s homes and supported accommodation services and can be adapted to reflect your organisation, the surveillance systems you use and your individual service arrangements.
Recording, storage and access
Images, recordings and other surveillance information should be securely stored and used only for their stated purpose.
Information should only be retained for as long as necessary.
CCTV monitoring screens should only be accessible to staff who need to view images as part of their role and should be located in an area that provides appropriate privacy.
Personal mobile phones or other personal devices must not be used to carry out surveillance activity.
Providers should also have clear arrangements for sharing footage, including circumstances where recordings may be required as evidence within court proceedings or safeguarding investigations.
Staff training is essential
Staff responsible for accessing or managing surveillance information should receive regular and up-to-date training.
This should include how to respond to requests to access recordings, when information can be shared, how complaints about surveillance should be managed and what action should be taken if a child or parent withdraws consent.
Managers should be confident that staff understand both the safeguarding purpose of surveillance and the limitations placed on its use.
More broadly, surveillance should not be considered in isolation. Staff understanding of safeguarding, children’s rights, risk assessment, professional curiosity, information sharing and effective recording will all influence how decisions are made and evidenced in practice.
A useful compliance check for providers
If your service uses CCTV or any other form of surveillance or monitoring, consider asking:
Can we clearly explain why it is necessary, why a less intrusive option would not achieve the same outcome, and how we regularly review whether it is still justified?
If the answer is unclear, your surveillance arrangements, risk assessments, staff knowledge and policy may require review.
How Social Care Skills can support your service
Understanding Ofsted guidance is only part of the challenge. Providers also need to ensure that policies, staff knowledge and day-to-day practice consistently reflect regulatory expectations.
Social Care Skills provides specialist training and consultancy for children’s homes and supported accommodation services, supporting providers, managers and staff to strengthen practice and prepare for regulatory scrutiny.
Our training offer includes live online seminars, bespoke training and face-to-face workshops. We support workforce development across areas including safeguarding, children’s rights, risk assessment, professional curiosity, regulatory compliance, recording and reporting, leadership and inspection readiness.
Bespoke training can also be developed around specific areas of practice, identified workforce development needs or concerns emerging from audits, incidents, internal quality assurance or Ofsted feedback.
Through our consultancy, compliance audits and policy review services, we support providers to evaluate how regulatory expectations are translated into practice. In relation to surveillance and monitoring, this may include reviewing policies and procedures, risk assessments, care or support planning, staff understanding, recording arrangements and the evidence available to demonstrate effective management oversight.
Our wider consultancy support can also help providers strengthen governance, quality assurance, leadership practice and inspection readiness across their service.
Whether you are preparing for an Ofsted inspection, responding to an identified compliance concern or simply reviewing the quality of your current arrangements, Social Care Skills can provide practical, sector-specific support.
Need support with training, compliance or inspection readiness? Contact Social Care Skills to discuss how we can support your service.
Read the full Ofsted guidance
Providers and managers should read the full Ofsted guidance, Surveillance and monitoring in residential childcare settings, and review their current arrangements against the principles and expectations set out by Ofsted.
https://www.gov.uk/guidance/surveillance-and-monitoring-in-residential-childcare-settings
