I think this depends - but on balance I would say that there are no privacy issues here. If the car is distinctive - let's say a Pink Rolls Royce, then it might be argued that it could fall within the other information provisions, but I still don't think it would be personal data. I would argue that even if the reg plate is visible that it is not personal (but will fall under other information provisions).
The registration on a car does not tell you the owner. The information you get from the DVLA if you legitimately enquire, does not give you the owner - only the "registered keeper" (and these two are not necessarily the same person). We own a car with these characteristics and also, if you lease a car you will often not be the owner. This just leaves the distinctiveness of the car and even that is tenuous for privacy implications, especially with no plate markings visible.
As ever though - treat each case on its own merits.
Simon Howarth
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Lindsay Foody
Sent: 06 November 2012 08:23
To: [log in to unmask]
Subject: [data-protection] CCTV and personal data
Would the image of a data subject's unattended car parked on a public road, and caught by CCTV, constitute personal data if the number plate cannot be identified from the footage, but the data subject has described the car and where / when it was parked? Would this info about the car be caught by the "other information which is in the possession of, of likely to come into the possession of, the data controller"?
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