The Council manages home school transport for pupils and contracts with coach companies. The contract requires that "Coaches and buses should be fitted with CCTV cameras with record and review facility." Although not stated the purpose is clearly for monitoring behaviour and reporting on bad behaviour.
Is the Council a (joint? ) data controller for the images so recorded ? Have we determined "the manner in which any personal data are to be processed" ?
Does it matter that the contract only requires that they be fitted - not that they be used ? Sloppy drafting as the intention is clearly that they should be so used.
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