Boots Members – Midlands & North Eastern Divisions

To:              All Mandate Members

Re:              Boots – Security Rule Changes

From:         Amanda Kane & Keith Pollard, Divisional Organisers

Date:          17th May 2021


Dear Member,

Please see below for your information, copy of correspondence between Mandate and Boots regarding 2021 Security Rules.

Should you have any queries regarding this matter, please contact the undersigned on (01) 8870708.

Yours fraternally,

Amanda Kane, Divisional Organiser, Mandate (Midlands Division)
Keith Pollard, Divisional Organiser, Mandate (North Eastern Division)


Ms. Rachel Nolan
HR Operations Manager
Boots Ireland
2nd Floor, 5 Riverwalk
Citywest Business Campas
Dublin 24.


14 May 2021

RE:         Security Rule Changes

Dear Ms Nolan

Further to my letter of the 1st April 2021 regarding the unilateral changes to the security rules and your response of the 10th May 2021, Mandate’s concerns have still not been addressed in full. The previous policy prior to March 2021 in relation to the use of CCTV footage, confirmed that this manner of surveillance would only ever be used in the context of investigations being conducted in theft and fraud investigations, however the most recent update to the security rules suggests a broader application of CCTV usage.

While the company have confirmed that the use of audio is triggered only by the panic alarm being pressed, the use of CCTV surveillance and footage has now been given broader scope to include the reviewing of merchandising planograms and promotional paraphernalia, which seems to be unnecessary and an extreme use of this technology. The policy update goes on to suggest that there are processes in place to ensure that this type of monitoring is carried out appropriately and  with minimum impact on colleagues’ privacy, however the policy doesn’t explain in any way what those processes are. On plain reading of the update, the common concern is that recordings of this nature could include footage of both our members and your customers, which we believe is an unacceptable use of CCTV and could be a possible breach of Data Protection legislation.

In addition to the above the updated policy states that “CCTV may also be used where necessary and appropriate, in the context of a disciplinary process or company investigation”. Mandate has immediate concerns about this development.  Mandate believes that the use of CCTV surveillance for performance related issues that may or may not be disciplinary in nature is unacceptable and an invasive use of this technology. Heretofore, the use of CCTV surveillance was referred to in the context of theft and fraud investigations only, however these developments have given rise to concerns being raised by the workers across the Boots business.

In light of the above, we would ask the company to review these concerns and as requested previously refrain from implementing same until the issues have been addressed. These matters raised above are Data Protection concerns that have far reaching implications, which our members believe could give rise to unreasonable intrusion into their privacy and data protection rights as individuals and as such, any excessive monitoring or surveillance, as suggested above should not take place.

Yours sincerely

For Mandate Trade Union
Jonathan Hogan
National Coordinator

Jonathan Hogan
National Coordinator
Mandate Trade Union

By Email

10th May 2021

Re: Boots Ireland Security Rules

Dear Mr. Hogan,

Thank you for your letter dated April 1st 2021.

In your letter you enquired re. the rollout of the Boots Store Security Rules and the CCTV section and the use of audio recording.

At Boots all team members have special responsibilities that include being entrusted with money and merchandise and as everyone shares these responsibilities, we have a set of rules to make sure team members can carry out their work confidently and are safeguarded. The security rules are regularly reviewed and updated, and team members are briefed and given a copy of the rules and asked to sign to confirm they have read and understood the rules. If they have any questions they are encouraged to speak to their line manager. It is a requirement of working for Boots that team members sign their acceptance of the Security Rules. There has been no change to this process in 2021 from previous years.

The wording in the CCTV section of the Security rules mirrors the wording in the company Worker (Privacy) Policy which is available on the company intranet BootsLive. This policy tells team members which type of information we hold, how we use it and how that might affect privacy.

I can confirm that audio recording is used when required for the safety of team members and customers. Audio only begins to record once a panic alarm is pressed. Unless the audio is requested within 30 days of it being recorded it will auto-delete as per our standard CCTV retention periods. Audio recordings are not accessible at store level.

I trust that the above answers your queries and I can reassure you that there have been very few queries from team members on this annual process.

Yours sincerely,

Rachel Nolan,
HR Operations Manager, Boots Ireland.

1st April 2021

Ms Rachel Nolan
HR Operations Manager
Boots Ireland

By Email Only.

Re: 2021 Security Rules Update

Dear Ms. Nolan,

Further to the company’s announcement over the past week regarding updates to the Boots security rules, a number of members across the stores have raised concerns in relation to these developments and the requirement by the company for them to sign a declaration form attached, confirming their acceptance of same. During my discussions with colleagues, it has been made clear to me that fears are been raised in relation to the use of CCTV and the specific mention in the policy update, regarding the use of audio recording.

In addition to the above, issues have been made in relation to the manner in which this update is being rolled out in stores, resulting in no consultation with staff and a forceful approach by store management for staff to sign and accept the document, when clearly they have outstanding questions and apprehensions that need to be addressed by their employer. Given that this document is a declaration of understanding requiring our members to sign it in that context, I would ask the company to refrain from the immediate implementation of this policy update, listen to the concerns raised by our members at both national and at store level and amend the policy to reflect the feedback from your staff.

Yours sincerely

Jonathan Hogan
National Coordinator

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