Privacy Impact Assessment Conducting a privacy impact assessment on surveillance camera systems (CCTV) Principle 2 of the surveillance camera code of practice states that the use of a surveillance camera system must take into account the effect on individuals and their privacy, with regular reviews to ensure its use remains justified. The best way to ensure this is by conducting a privacy impact assessment before the system is installed and when a new camera is being added on to an existing system. This will assist in managing any privacy issues the use of the surveillance system might have. A Privacy Impact Assessment enables operators to unpick risks to compliance with the Data Protection Act and the Human Rights Act. The PIA should initially consider the pressing need that the system seeks to address and the impact that recording may have on individual’s privacy. It is important to decide whether the proposed system can be justified as proportionate to the needs. In undertaking a Privacy Impact assessment you must take into consideration your obligations under the Data Protection Act 1998 and follow the guidance provided in the ICO’s . This privacy impact assessment template is specifically for those organisations that must have regard to the surveillance camera code of practice under the PoFA. It also helps organisations to address their data protection and human rights obligations. A PIA does not always have to be conducted as a completely separate exercise and it can be incorporated into project planning or management and review activities. In deciding whether to conduct a PIA and its scope, consideration must be given to the nature and scope of the surveillance camera activities and their potential to impact on the privacy rights of individuals. A PIA should be considered when you are reviewing your surveillance camera systems and when you are considering introducing new technology allied to them. A Privacy Impact Assessment should be considered when any of the following apply: When you are introducing a new surveillance camera system If you are considering introducing new or additional technology that may affect privacy (e.g. ANPR, Body worn cameras, remotely operated vehicles (drones), megapixel or multi sensor very high resolution cameras). When you are changing the location or field of view of a camera or other such change that may engage privacy concerns.
4 Re-Deployable PTZ CCTV Samsung Tyco Mini Mobile PTZ RDC 14 LBI SYSTEM CAMERAS – ALL TYPES 179 Step 2 (location assessment) Location: Each system operator/owner should list and categorise the different areas covered by surveillance on their system. This list should use the specifications above which ID (types) are used at each specific location. Cat Location Type Camera Types used Amount Recording Monitoring Assessment of use of equipment (mitigations or justifications) A Main thoroughfares containing businesses, retail and residential areas PTZ Dinion 610/11 Bosch static Dinion Philips Dinion 600 PTZ Bosch Mic1 300 PTZ 133 24 hrs. – patrols every shift and as required based on intelligence or other information Islington is a Borough where businesses, retail and residential areas combine together. The privacy level expectation in these areas is very low; These areas are well signed with appropriate signage for CCTV its use and purpose with contact details. However all recording and evidence downloads are locked down and only managed by LBI within the control room.
Bosch Mic1 400 PTZ Predator PTZ Bosch Mic1 500 PTZ B Public Car Parks Bosch PTZ Dinion 610/11 1 24hrs 24 hrs. – patrols every shift and as required based on intelligence or other information The privacy level expectation in a public car park is very low. These areas are well signed with appropriate signage for CCTV its use and purpose with contact details. However all recording and evidence downloads are locked down and only managed by EPSC staff/ police C Parks Bosch Mic1 400 IRS PTZ Bosch Mic1 400 PTZ Bosch PTZ Dinion 610/11 6 24 hrs. – patrols every shift and as required based on intelligence or other information The privacy level expectation in a public park is low; These areas are well signed with appropriate signage for CCTV its use and purpose with contact details. In some of the parks residential areas can also been seen D Residential Street Mic1 400 PTZ Mic1 300 PTZ Bosch PTZ Dinion 610/11 16 24hrs 24 hrs – patrols every shift and as required based on intelligence or other information Public Protection Cameras are installed on identified crime or ASB areas in estates and residential streets in order to assist in crime detection, incident and estate management. Usually PTZ cameras but may include some fixed camera types for specific view point capture. Some residential area PTZ cameras
Agreed with Sean Tuckey – Responsible PSS system owner Signature…………………………………………………………… Date 06.10 2016 Completed copy sent to CCTV SPOC (PSS Manager) by e-mail on 6/10/2016 for inclusion on Islington CCTV Register Review date 06.10 2017