In a message dated 15/03/2002 11:07:21 GMT Standard Time,
[log in to unmask] writes:
<< Colette, I've been wrestling with this lately too - in respect of Community
Safety partnership, Youth Offending Teams and the CCTV partnerships between
Council, Police Force & Police Authority. >>
---------
It has already been established that YOTs are separate data controllers and a
notification template for them can be found on the OICs website.
It may be that other partnerships are on a data sharing basis between
controllers in common or joint controllers but the reps from each controller
should be made aware of restrictions on secondary use. For example, if the
CCTV scheme is for crime detection and prevention purposes (and you make use
of the exemption from the first principle) then the video images could not be
used by the council for personnel use (e.g. we caught X on tape selling stuff
on the market while he was off sick) or civil actions. Police may not be
happy to allow use of cctv for non-crime purposes such as contract compliance.
Remember also that community safety would be interested in reducing disorder
as well as crime and that would not qualify for an exemption from the first
principle.
Where cctv control rooms are in council premises and personned (is that a
real word?) by council staff or contractors, the identity of the sole data
controller is obvious but where (for example) police officers have unfettered
access to the control room and can switch or pan cameras according to their
needs they are probably joint data controllers, although some forces don't
like the joint liability aspects of this arrangement.
Ian Buckland
MD
Keep IT Legal Ltd
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