Jon,
Thanks for the email. Yes, the PII would need to be provided. I was raising the issue as it would appear that many organisations are unprepared in that they may be unaware that their data systems link to their CCTV. I would suggest that a lot of organisations rely on CCTV without understanding the full impact that has on their need to comply with the new DPA/GDPR.
Most councils will fall into the scenario I sketched early so they will need to have the facility to provide the CCTV footage as a standard part of any SAR. I don’t know how many are ready for that. Perhaps they are already providing CCTV as a standard part of their SARs. I don’t know as it was never mentioned previously. I know people are prepared to provide CCTV if asked directly but not usually as part of a “I want my data” type of request especially if they interact with other data systems such as contact points or interviews on council properties.
Best,
Lawrence
Lawrence Serewicz
Information and Records Manager
Transformation and Partnerships
Durham County Council
County Hall
Room 143-148 4th Floor
Durham
County Durham
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www.durham.gov.uk
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From: Jon Baines [mailto:[log in to unmask]]
Sent: 20 March 2018 13:41
To: Lawrence Serewicz <[log in to unmask]>
Cc: [log in to unmask]
Subject: Re: [data-protection] Follow up on CCTV and SARs
Why would they not provide the footage? If it’s personal data (nb “PII” is not equivalent to “personal data”) it’s within the scope of a subject access request, as a starting principle. Why does GDPR/DP Bill make a difference?
Jon Baines,
Chair,
nadpo.co.uk<http://nadpo.co.uk>
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