I've just scanned the DPO web site looking for the Draft University
Notification document to no avail, so I've emailed asking for a url.
What I did find was the guidelines on CCTV and I am staggered.
Am I alone in thinking that it's a bit OTT? Somebody tell me that I'm
dreaming please and that this 98 act has been taken out of all proportion?
The guide tells you in precise detail how to run a CCTV system.
- Signs must be at least A3 size (note: not 'appropriate' size)
- tapes must be used no more that 13 times. That rather depends on the
quality of the tapes and the equipment, the investment you can make, the
value of the deterrent to you.
- you should degauss before use (well it wouldn't work if you didn't would
it - that's why recorders have degauss heads activated during record
cycle!).
- cameras should not scan public areas - that might need an immediate
redesign of our systems.
- the assumption that the display equipment is in a dedicated room
- etc
I'm not sure that the DP office are good authorities on such matters, nor
should they claim to be.
What is not mentioned, and is within their expertise, is the question of
whether this act should be applicable at all in cases where automatic
recognition of subjects is not possible and how anyone can realistically
respond to a request. The EU directive seems to exclude such automated
equipment since the data is not structured - it seems to me that there has
been a mistake in the 98 act in that 'structured' only applies to manual
data.
After all, if you ran a system with (say) a monthly cycle of tapes how
could you sensibly respond to a subject saying they wanted copies of all
images held? If they mention an incident at a particular place and time,
that's a different matter.
Phil
--
Phil Brady
Information Services
University of Wales Bangor
Adeilad Deiniol
Deiniol Rd.
Bangor LL57 2UX
Tel +44 1248 382960 Fax +44 1248 383826
Email [log in to unmask]
%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%
|