Smart doorbells (commercial use)
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Due to the Data (Use and Access) Act coming into law on 19 June 2025, this guidance is under review and may be subject to change. The Plans for new and updated guidance page will tell you about which guidance will be updated and when this will happen.
☐ We have conducted a Data Protection Impact Assessment (DPIA) that fully addresses our need to use smart doorbells, the lawful basis for their use and explores the impacts on the rights and freedoms of individuals whose personal data are captured.
☐ We appropriately position our smart doorbell in such a way that the camera does not inadvertently record neighbouring entrances or private property, that are not the intended subject of surveillance.
☐ We ensure that any footage that we record, is kept securely and is appropriately governed in terms of retention, security, disclosure and access.
☐ We ensure that any smart doorbell apps we use, or associated software, is secure and kept up-to-date with the latest patches by checking communications from the manufacturer or vendor.
☐ We place appropriate signage to inform individuals that surveillance is in use where doorbells are located.
☐ We limit any continuous recording, and the possible intrusion of others, by only having the camera activate when the doorbell is pressed.
☐ We comply with the Surveillance Camera code of practice where required.
What is a smart doorbell?
Smart doorbells utilise the positioning of traditional doorbells, and incorporate cameras that can capture images and sometimes audio of individuals visiting or leaving your premises. Some designs can offer a high definition field of vision up to 180 degrees, which can also allow you to see individuals at the door from head to foot.
Often, smart doorbells also connect to a mobile app which can allow you to:
- view a live feed from a remote device;
- save and edit any recorded footage; or
- even potentially share recorded footage with others such as insurance companies or law enforcement.
If you are considering using a smart doorbell for business purposes, it is important that you think about the capabilities of the camera prior to its use. For example, the field of vision it offers and the potential privacy intrusion of others.
As with most video surveillance systems, it is important that you carry out a DPIA that fully addresses:
- your need to use smart doorbells;
- the lawful basis for their use; and
- explores the impacts on the rights and freedoms of individuals whose personal data are captured.
Some models of smart doorbells can be also equipped with facial detection and recognition technologies, which give you the capability to automatically identify an individual at your door. For example, the software may assist access through the door itself by verifying the identity of a visitor. Or more commonly, it may alert you to a specific person of interest if they visit the property. This can be done via a mobile app.
If your system is designed to uniquely identify individuals through technologies like facial recognition, then you are also likely to be processing special category data. Therefore, you need to have further protection and safeguards in place. See our guidance on special category data.
It is important that you position your smart doorbell in such a way that the camera does not inadvertently record neighbouring entrances or private property, that are not your intended subject of surveillance.
Example
The owners of a private office building wish to install a smart doorbell at their entrance to increase security, so reception staff only let in recognised clients.
The office entrance is located directly opposite another private building, and it is possible for the camera to see into the windows of the other premises.
The business owners ensure that the smart doorbell is positioned side on, in such a way that the field of vision only captures those that stand at the doorway. In addition, the owners ensure that the camera is only activated when the doorbell is pressed, so they are not using continuous recording.
They also place a sign that reminds visitors about the use of a surveillance system at the entrance to the office building.