Many childcare operators choose to combine their CCTV policy and personal device policy into a single document — a ‘Digital Technologies and Surveillance Policy’ — rather than maintaining two separate policies. This is a sensible approach that reduces policy proliferation while addressing both areas comprehensively.
This guide covers what a combined digital technologies policy must include to satisfy the NQF requirements for both CCTV governance and personal device restrictions, and provides a section-by-section template structure you can adapt for your centre.
Why Combine CCTV and Digital Device Policies?
The September 2025 NQF amendments addressed CCTV use and personal device restrictions under the same Quality Area 2 digital safety framework. Both policies govern the use of digital and electronic technology in children’s spaces, both require staff training and documented review cycles, and both connect to the same child safety rationale.
Combining them into a single, well-structured policy document makes it easier to maintain currency, easier to train staff on the full picture of digital safety obligations, and cleaner to present during an assessment visit.
Template Structure: Digital Technologies and Surveillance Policy
Section 1: Purpose and Scope
State the purpose of the policy — to govern the responsible use of digital technologies and surveillance systems at the service in a manner that protects children’s safety and privacy. Specify which technologies are covered: CCTV systems, service-owned digital devices, and personal devices.
Section 2: CCTV Surveillance
This section should address:
- Purpose of CCTV: Child safety monitoring, perimeter security, incident documentation
- Camera placement: Where cameras are located, what each covers, and areas where cameras must not be installed
- Data retention: How long footage is stored, where it is stored, and the process for secure deletion
- Access authorisation: Which roles may access footage, under what circumstances, and the process for documenting access
- Parent notification: How families are informed that surveillance is in operation and their rights regarding footage
- Connection to incident response: How CCTV footage is used in incident documentation and notification
For the full breakdown of what each of these sections must contain, see our CCTV policy requirements guide.
Section 3: Service-Owned Digital Devices
Describe which digital devices are owned and provided by the service (iPads, tablets, computers, centre phones), how they are to be used, who is authorised to use them, and the process for reporting damage, loss, or inappropriate use.
Section 4: Personal Device Restrictions
This section addresses the September 2025 personal device ban:
- Prohibited devices: Personal mobile phones, personal tablets, personal smartwatches in children’s spaces
- Restricted areas: All areas where children are present; specify any additional restricted areas
- Permitted exceptions: Emergency communications only — define what constitutes an emergency and the required process
- Break time use: When and where staff may use personal devices during designated break times
- Consequences for breach: The disciplinary process for policy violations
See our personal device ban guide for detailed implementation guidance.
Section 5: Staff Training and Acknowledgement
State that all staff are required to read, understand, and acknowledge this policy as part of induction and at each annual review. Training records must be maintained showing that each staff member has acknowledged the policy in the current review period.
Section 6: Policy Review and Currency
State that this policy will be reviewed annually and when there are material changes to the relevant legislation, the physical environment of the centre, or the technology systems in use. Record the date of each review on the policy document.
Section 7: Related Policies and Procedures
Link to your incident response procedure, your child safe environment policy, your privacy policy, and any other policies that interact with digital technology and surveillance governance.
Common Policy Weaknesses to Avoid
- Policies that describe obligations but do not specify the process for meeting them (e.g. ‘footage may only be accessed by authorised staff’ without specifying who authorises access and how it is documented)
- Policies that address CCTV placement in detail but say nothing about data retention or deletion
- Personal device sections that list prohibited devices but have no provision for emergency communications
- Policies with no connection to the incident response procedure
- Undated policies, or policies with no record of when they were last reviewed
Keeping the Policy Current
A policy that does not reflect current practice or current legislation is worse than no policy in an assessment context — it signals to assessors that governance is not actively managed. Schedule an annual policy review, document the review outcome regardless of whether changes are made, and update the ‘last reviewed’ date on the policy document.
For the full picture of your digital safety compliance obligations within the NQF, see our NQF child safety compliance guide.
Summary
A well-structured Digital Technologies and Surveillance Policy demonstrates to assessors that your service has thought carefully about the full scope of its digital safety obligations under Quality Area 2. It is one of the cleaner wins available in your compliance documentation — a single, well-drafted document that satisfies two NQF requirements simultaneously. Combine it with real-time CCTV alert management and you have both the policy and the system that makes the policy operational.
Book a free SafeDay compliance review and discuss your digital technology policy with our team.
