Responses so far have indicated that:-

1. Only the first two screens (or images on video??) on the system actually
named the individual, but a further five screens were accessed directly from
the first two.  These extra screens (or surrounding objects/buildings??)
related purely to the application's progress through the committee
procedures and no reference number from these screens related to the
applicant.  The logic of the system was that they were a natural progression
and therefore they were classed as personal data.

2. If an individual request images from CCTV how are we to have a context.
I do believe that the issue should
be one of removing third party details only, the location and any other
captured data should be intact.

3. We will then view the video footage and where we are SURE the person can
be postively identified we will send a recording of that bit of the tape. At
present we do not exclude other individuals' images. This is on the grounds
that they were in a public place, they knew they were likely to be on CCTV
(from the displayed signs) and the data subject would have seen them anyway.

It was also raised about potentially claiming a 'crime prevention' exemption
for in store videos, using the argument that there was a possible
opportunity to identify the exact coverage of the cameras from a subject
access request.  This sounds as though it would be extremely difficult to
justify as a standard policy.


The context of the recording appears to be a most important element, even
with regarding the remark about a potential exemption.  My interpretation of
all responses so far, is that they have said, in different ways, that
associative data, i.e. putting the data subject in context, is personal data
with respect of video recordings.  My apologies to respondents if I have
interpreted them incorrectly in this.

Will keep you updated if there are any further developments.


Ian W.

----- Original Message -----
From: <[log in to unmask]>
To: <[log in to unmask]>
Cc: <[log in to unmask]>
Sent: Monday, April 30, 2001 10:50 AM
Subject: RE: Subject Access - Video Recordings


> Ian
>
> I would be very interested in what advice etc you get back on this
> one please.
> Luckily I haven't had one of these requests!
>
>
> # >1.  What constitutes personal data when an individual is in a public
place?
> yes indeed.
>
> # >2. Is the location information, or are the surroundings where an
individual
> # >is positioned personal data?
> again interesting question!
>
> Sally

^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
    If you wish to leave this list please send the command
       leave data-protection to [log in to unmask]
            All user commands can be found at : -
    www.jiscmail.ac.uk/user-manual/summary-user-commands.htm
all commands go to [log in to unmask] not the list please!
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^