We are looking at this issue. We are of the view that a SAR is to obtain a copy of information about the data subject. In terms of section7(4) the personal data of third parties should only be provided where the Council cannot comply with the SAR without disclosing the information and either that person has consented (unlikely) or in all of the circumstances it is reasonable to do so.
Generally the purposes of CCTV is to monitor the behaviour of each individual caught in the images. Consequently, if you can comply with the SAR without disclosing it, all images in relation to others must be rendered unidentifiable - usually through pixellation or just blacking out part of the images.
In a case of a motoring incident (to which a large amount of these requests relate) we would provide copies of the images of the person making the request but then have to consider whether the other images are the personal data of the requestor and the answer is probably not. In that case, you cannot provide those images under section 7 of the DPA.
However, this does not prevent the possibility of data sharing (rather than responding to a SAR) in relation to the others. This would involve looking at the principles etc. (taking account of section 35(2)) and deciding whether to share the information of the others. One "benefit" to this approach would be to potentially allow you to charge for providing the images (and that would be more than £10 especially when this fee goes from May 2018). Of course setting the level of the fee would need to be carefully set so as to discourage lawyers from seeking court orders for its production to them.
We are still looking into this matter with an eye to the changes next year.
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