We all need to be aware of the Home Office CCTV Code, which, I think, has not commenced yet, but must be imminent. It's sensible stuff and I think the overarching point is that policies need to be clear and a) justify the use of CCTV and b) describe how any CCTV will be operated (this would include responding to requests for footage).
I think all current and future CCTV should be subject to PIAs (including retrospective ones) and supported by clear policies.
https://www.gov.uk/government/news/surveillance-camera-code-of-conduct-comes-into-force
Jonathan Baines
Complaints and Information Rights Officer
Legal and Democratic Services
Buckinghamshire County Council
01296 383681
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-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Nic Drew (Cardiff and Vale UHB - IT Security)
Sent: Tuesday 30 July 2013 11:46
To: [log in to unmask]
Subject: Re: [data-protection] CCTV
If you don't accept the proof of ownership/proof of ID from the victim, then it is highly unlikely that you are processing personal data and as such do not have to provide images (as there is no personal data in your possession) . If you only have 1 or 2 of these requests in a year then it is not too much trouble to process; however if you have a large site with lots of through traffic and 3000+ parking spaces (and therefore lots of driving/parking bumps) you probably don't want to respond to lots of CCTV SAR's!
Nic Drew
Data Protection Manager
Cardiff and Vale University Local Health Board
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Owen Thomas
Sent: 30 July 2013 11:20
To: [log in to unmask]
Subject: Re: CCTV
This actually gets interesting if you think about it in terms of the definition of personal data.
In an RTA case where the collider drives off, CCTV footage might show the individual, their vehicle / registration and possibly face - but unless the data controller has other info that would allow identification of that person, it's not 100% clear that the footage would necessarily be the personal data of said scallywag.
The victim, however, comes to the data controller with details of his vehicle, proof of ownership (or, at least, a copy of the V5 in his name), proof of his own ID and details of when and where his vehicle was damaged, which allows particular segment of CCTV footage to be isolated. Footage then becomes the personal data of the victim, does it not?
As such, does he not have Section 7 rights we should be considering here?
Owen
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