A couple of our CCTV users don't record the images displayed.
e.g. a simple camera and screen to monitor access to a building.
No need (or ability) to record.
Our existing code of practice was really designed to cover the recording of images.
So I'd like to update it to also reflect these circumstances.
But I'm unclear to what extent DPA98 would apply.
Is this personal data?
Well..... the person looking at the screen could certainly recognise an individual.
Obviously though its not in any kind of filing system (let alone a relevant one),
so things like subject access are not relevant.
But if its covered by DPA98 there would still be other requirements (e.g. signs).
hmmm........
any guiding comments would be appreciated.
thanks
Tommy Kennedy
DPO
South Ayrshire Council
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