Apologies about the particularly bad and misleading example in the last
paragraph of my previous message, mental abhoration as a result of a
particular concern.

Ian W.

----- Original Message -----
From: "Ian Welton" <[log in to unmask]>
To: <[log in to unmask]>
Sent: Sunday, April 29, 2001 5:45 PM
Subject: Re: Subject Access - Video Recordings


> The bluring was carried out by focusing on the data subject in a similar
> fashion to looking through a magnifying glass, everything but the data
> subject on the screen was then blurred.  All of the information about the
> data subject was, hence delivered.  Other information which was
associated,
> e.g. the many other persons in the vicinity, and as a by product the
> geographical features, were blurred.  What I considered as an 'exclusive'
> method - focus on the data subject exluding everything else.
>
> The technology achieved this in one sweep through a recording containing
all
> the extracts of the individual.  To have edited the extract recording
using
> an 'inclusive' method (separately blurring other persons) would have meant
> running the recording many times, focusing on individuals or groups each
> time to blur them during each re-run, probably ending up, in this
particular
> case, with a not to dissimilar final result, but having expended a
> significantly greater time to achieve it.
>
> The question of what information 'associated' with the data subject in a
> video is 'personal data', and what is not, appears to be key to the method
> which should be used.   Considering the DPA definition of personal data I
> currently have difficulty in seeing a sound argument that the geographical
> location is personal data in that context;  Although in a different
context,
> a written note about the location of an individual, linked to their
personal
> details is definitely personal data.
>
> My view is that other information on a video should be classified as
> personal data, not least because of the type of example you provide, funny
> how differently the logic of the DPA can be perceived sometimes.  Does
> geographical or other data on a video recording 'relate' to the data
> subject?
>
> I fully agree with your views regarding the deletions from a database, but
> can see similarities in the video scenario with the removal of purposes
from
> the notification process, without any reciprocal need to provide detailed
> advice of all of the purposes collected data is used for, within a subject
> access response.  Providing sources and disclosure, or the provision of a
> notification does not achieve this.
>
>
> Ian W.
>
> ----- Original Message -----
> From: <[log in to unmask]>
> To: <[log in to unmask]>
> Sent: Saturday, April 28, 2001 9:56 AM
> Subject: Re: Subject Access - Video Recordings
>
>
> > In a message dated 27/04/2001 21:27:17 GMT Daylight Time,
> > [log in to unmask] writes:
> >
> > << To save time and minimise cost the video recordings were
depersonalised
> by
> >  bluring all of the screen except for the image of the data subject.
This
> >  left the eventually disclosed material containing only the images of
the
> >  individual with everything else blurred.  I considered trying to only
> blur
> >  the faces of other individuals on the recording, but the resource costs
> >  would have increased from 2 hours to 1 day or more, for the
approximately
> 5
> >  minutes of recording contained in the extracts showing the data
subject.
> >>
> > ------------
> >
> > I would have thought that removing any more than 3rd party identities
> > (faces?) would be a breach of the Act.
> >
> > The location may have been necessary as (e.g.) an alibi.
> >
> > If the request had been for computerised data and you deleted everything
> but
> > the person's name and address you would certainly be in trouble!!
> >
> > Hope this is no too simplistic a view - any comments?
> >
> > Ian Buckland
> > MD
> > Keep IT Legal Ltd
> >
> > Please Note: The information contained in this document does not replace
> or
> > negate the need for proper legal advice and/or representation. It is
> > essential that you do not rely upon any advice given without contacting
> your
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> >
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