They way I've always looked at this is that you are potentially processing special category data (disability, religion, ethnicity), but you aren't setting out to do it or doing it on purpose. Consequently, you can avoid saying you are processing special category data, simply personal data. It gets problematic when you are told that a one-legged man wearing a turban is causing a disturbance - you are probably processing special category data when you start looking for that individual -unless, of course, the person is in fancy dress and isn't actually one-legged...
Donald
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Bill Dunn
Sent: 13 November 2018 16:36
To: [log in to unmask]
Subject: [data-protection] Very Early Friday Question
Hi,
Looking for a bit of guidance about something that probably hasn't changed with the GDPR.
We operate open space CCTV cameras for the purposes of prevention of anti social behaviour. These cameras monitor public spaces. Would images of people with disabilities amount to special category data? The purpose of the processing is unconnected with their disabilities. This could make the images personal data.
Would it be different if we were broadcasting public Council meetings from our website and that an attendee at the meeting was disabled?
Thanks
Bill Dunn
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
All archives of messages are stored permanently and are
available to the world wide web community at large at
http://www.jiscmail.ac.uk/lists/data-protection.html
If you wish to leave this list please send the command
leave data-protection to [log in to unmask]
All user commands can be found at https://www.jiscmail.ac.uk/help/subscribers/subscribercommands.html
Any queries about sending or receiving messages please send to the list owner
[log in to unmask]
Full help Desk - please email [log in to unmask] describing your needs
To receive these emails in HTML format send the command:
SET data-protection HTML to [log in to unmask]
(all commands go to [log in to unmask] not the list please)
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
Securing the future... - Improving services - Enhancing quality of
life - Making best use of public resources.
The information in this email is solely for the intended recipients.
If you are not an intended recipient, you must not disclose, copy,
or distribute its contents or use them in any way: please advise
the sender immediately and delete this email.
Perth & Kinross Council, Culture Perth and Kinross and TACTRAN do not warrant that this email or any attachments are
virus-free and does not accept any liability for any loss or damage
resulting from any virus infection. Perth & Kinross Council may
monitor or examine any emails received by its email system.
The information contained in this email may not be the views of
Perth & Kinross Council, Culture Perth and Kinross or TACTRAN.
It is possible for email to be falsified and the sender cannot be
held responsible for the integrity of the information contained in it.
Requests to Perth & Kinross Council under the Freedom of
Information (Scotland) Act should be directed to the Freedom of
Information Team - email: [log in to unmask]
General enquiries to Perth & Kinross Council should be made to
[log in to unmask] or 01738 475000.
General enquiries and requests under the Freedom of Information (Scotland) Act
to Culture Perth and Kinross should be made to
[log in to unmask] or 01738 444949
General enquiries to TACTRAN should be made to
[log in to unmask] or 01738 475775.
Securing the future... - Improving services - Enhancing quality of
life - Making best use of public resources.
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
All archives of messages are stored permanently and are
available to the world wide web community at large at
http://www.jiscmail.ac.uk/lists/data-protection.html
If you wish to leave this list please send the command
leave data-protection to [log in to unmask]
All user commands can be found at https://www.jiscmail.ac.uk/help/subscribers/subscribercommands.html
Any queries about sending or receiving messages please send to the list owner
[log in to unmask]
Full help Desk - please email [log in to unmask] describing your needs
To receive these emails in HTML format send the command:
SET data-protection HTML to [log in to unmask]
(all commands go to [log in to unmask] not the list please)
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
|