In a message dated 31/05/2001 12:18:46 GMT Daylight Time,
[log in to unmask] writes:
<< The Commissioner's Code, as I read it, doesn't require the signs used for a
cctv scheme to make clear the purposes of the cctv scheme; at least where
the sign has an image of a camera. >>
-----
I disagree. The code clearly states:
"The signs should contain the following information:
a) Identity of the person or organisation responsible for the scheme.
b) The purposes of the scheme.
c) Details of whom to contact regarding the scheme.
(First Data Protection Principle)"
In the example given after that bit of the code, in relation to a sign using
an image of a camera ("This scheme is controlled by the Greentown Safety
Partnership. For further information contact 01234-567-890") the purpose is
obvious in the title of the organisation managing the scheme.
Other organisations such as local authorities have a number of statutory
duties, local responsibilities and they also undertake some commercial
activities. It would not be obvious from a picture of a camera and the name
of the council what the images are to be used for.
Can you imagine a council using stills from CCTV images of a town/city centre
event to publicise the event? Oops, too late, it's already been done. Can
you imagine two people complaining because in the picture they appear to be
holding hands even though they are married - but not to each other? Oops,
too late, it's already been done.
Where the images are only to be used for crime detection and prevention
purposes (not disorder as this is a civil offence), and there is evidence of
such in the area, you may qualify for an exemption under the First Principle.
Otherwise, the information to be provided, as the law says, is:
"(a) the identity of the data controller,
(b) if he has nominated a representative for the purposes of this Act, the
identity of that representative,
(c) the purpose or purposes for which the data are intended to be processed,
and
(d) any further information which is necessary, having regard to the specific
circumstances in which the data are or are to be processed, to enable
processing in respect of the data subject to be fair."
Don't blame me, I'm only a messenger.
Ian Buckland
MD
Keep IT Legal Ltd
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