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"We have used images to identify individuals carrying out vandalism - and
work on the basis that the images become personal data at that stage.
Individuals are then told this data is held on them and comes under the Act
etc etc"

Some thoughts arising from that wording...
What arguments are used to base the application of the personal data
definition at the point when vandalism has occurred and is being
investigated rather than when the data is collected? Would the purpose(s)
not define the collection as necessarily containing personal data as defined
by DPa 1998 s.1?
Does the organisation hold photographs of staff and students? If it does how
are DPA 1998 s.1 personal data definition issues then measured against that.

Ian W



Date:    Thu, 1 Feb 2007 15:50:44 +0000
From:    Bridget Brook <[log in to unmask]>
Subject: CCTV Policy

Good Afternoon

I'm just reviewing our CCTV Policy and as often happens a couple of issue=
s=20 have come up at the same time

We use CCTV to protect buildings, staff and students like everyone else=20=

does I'm sure.  We have used images to identify individuals carrying out=20=

vandalism - and work on the basis that the images become personal data at=
=20 that stage. Individuals are then told this data is held on them and
comes= =20 under the Act etc etc

We have had a request to provide evidence to prove the time a staff membe=
r=20 was on site - this can be available from viewing the camera at the=20
entrance. Can anyone give me some quick advice on whether this is=20
acceptable and what action needs to be taken if this route is taken - if=20=

indeed it can be. Should we have had anything in place in advance of
his=  -=20 the IC's office says it's only at this point that we would need
to take=20=

action but should it be in the Staff Handbook?

Apologies, I'm sure this is a very basic topic for many of you but it's n=
ot=20 one I've had to deal with before

If anyone is willing to share their CCTV policy with me I'd be very=20
grateful also

Thanks in anticipation

Bridget Brook
Central Services Manager
Sparsholt College

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