It would be likely to reach the grade as personal data, if living individuals could be linked to the image using it and / or other data.
Would publishing the image to a web page therefore constitute a DPA breach? I think it would depend on the context of the publication.
If the image is presented as 'generic Street X' within your area, accompanying a piece or page that is similarly beige / general info / doesn't contain or imply a message people could realistically get aerated or upset about, then no. However, if the image accompanied a piece about a particularly contentious topic and was presented (or could be inferred as being) 'Street Z - the one where all the wrong'uns live!', when it is actually 'generic Street X', then yes, I think that could perhaps constitute a complainable use of personal data in the form of residential imagery.
In general, you'd probably be looking at Legitimate Interests as a processing condition - provided the imagery doesn't get used in a way that tramples over residents' own rights and freedoms (such as the freedom not to be wrongly implied to be a wrong'un) I'd expect the usage to be okay.
Regards,
Owen Thomas
Deputy Data Protection Officer
Data Protection Office
People, Communications and Partnerships
Sunderland City Council
0191 5611263
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
All archives of messages are stored permanently and are
available to the world wide web community at large at
http://www.jiscmail.ac.uk/lists/data-protection.html
If you wish to leave this list please send the command
leave data-protection to [log in to unmask]
All user commands can be found at https://www.jiscmail.ac.uk/help/subscribers/subscribercommands.html
Any queries about sending or receiving messages please send to the list owner
[log in to unmask]
Full help Desk - please email [log in to unmask] describing your needs
To receive these emails in HTML format send the command:
SET data-protection HTML to [log in to unmask]
(all commands go to [log in to unmask] not the list please)
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
|