Dear all,
I recognise the IC latest CoP on CCTV as extremely beneficial to us as a local authority... but, find it hard to comply with (at present?!).
Since I have been making a enquiries within our Council for ensuring compliance on our registration/notification, I have found that the growth of CCTV was phenomenal over a relatively short space of time. Also it has come to light that various individual departments, Housing for example were responsible for a certain amount of CCTV, whilst Estates & Facilities were responsible for others, etc, etc. This is obviously uneconomic both in terms of resources and economies of scale. We now have a corporate CCTV strategy to ensure that existing and future schemes are in line with best practice.
I was wondering how many others have still not caught up with the 'Digital' age within CCTV and are still using VCR for recording, thus making it extremely difficult to pixel out 3rd parties in a video frame, how are you currently managing 'subject access requests' with this last point in mind.
Another issue which I have encountered and are currently trying to resolve is the legal ownership of cameras on our Estates in the borough, their Tenant Associations have installed the CCTV themselves and although they are happy for us to monitor them do not wish for us to take legal ownership, therefore where does responsibility lie for any 'subject access request's' ? As far as I am aware there was no CoP in place to ensure that privacy and civil liberties issues were safeguarded when schemes were introduced in residential areas. and Are the TA the Data Controllers and the Council the Data Processors ?. Although it seems fairly obvious who the DC should be.
( last thought is; Buildings with Concierges that have CCTV - have they got the equipment which ensures full compliance - SAR?)
After reading the Guardians story (1/3/01) I feel Newham are leading the way.
It would be comforting to know that I am not alone, and would be grateful for all comments.
Tracy Phillips
Data Protection Officer
London Borough of Hackney
E-mail: [log in to unmask]
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