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Help requested posted on 4th December 2017:

CCTV lollipop ladies

Struggling to answer some issues in respect of lollipop lady body cameras - has anyone else used these before and has procedures/data protection policies in place?

Clare Withington

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Response posted on 4th December 2017 by:
Ron Paterson

E: ron.paterson@westsussex.gov.uk
T:

CCTV lollipop ladies

Hi Clare
We launched a successful scheme working here in West Sussex using body-worn cameras. I no longer manage the SCP service but if you contact my colleague, Louise Bishop at louise.bishop@westsussex.gov.uk She'll be happy to help with what we did and possibly share some of our documents. I'd urge you to read the RSGB guidelines as a starting point as we based all of our work on those.Ron


Response posted on 5th December 2017 by:
Richard Hall

E: richard.hall@northlincs.gov.uk
T: 01724 297346

CCTV lollipop ladies

As Ron mentions there are the Road Safety GB Guidelines for the Use of Surveillance Cameras at SCP sites. These cover the legislation and processes you need to consider before going down this line. If you are looking to use footage for evidential purposes you will need to engage with the Police right from the start.
The Guidelines are available free to Road Safety GB members and can be found on the SCP page of the website(in the member's area).


Response posted on 21st December 2017 by:
Liz Mapstone

E: elizabeth.mapstone@n-somerset.gov.uk
T: 01934 426910

CCTV lollipop ladies

I had the following key points provided by the Council's Information Officer from the ICO’s Code of Practice on CCTV which section 7.2 (p27) provides some useful direction on the use of body worn video (BMV).

• it is important that you justify its use and consider whether or not it is proportionate, necessary and addresses a pressing social need.
• It is highly recommended that you undertake a privacy impact assessment to demonstrate that this is the case.
• Continuous recording will require strong justification as it is likely to be excessive and cause a great deal of collateral intrusion. This is because continuous recording is likely to capture people going about their daily business, as well as the individual who is the focus of your attention.
• Individuals using BWV systems should be able to provide sufficient fair processing to data subjects. As BWV cameras can be quite small or discreet, and could be recording in fast moving or chaotic situations, individuals may not be aware that they are being recorded. It is therefore important that clear signage is displayed, for example on an individual’s uniform, to show that recording is taking place and whether the recording includes audio. You should also think of ways to provide further information to data subjects if they wish to find out more information, for example, directing them to the privacy notice on your website, if you have one.
• Because of the volume of personal data and potentially sensitive personal data that BWV cameras will process and the portability of them, it is important that you have appropriately robust technical and physical security in place to protect this information. For example, make sure devices can be encrypted, or where this is not appropriate have other ways of preventing unauthorised access to information.
• As you may be recording a large amount of information, you need to ensure that you can store all of it and have a retention and disposal policy in place.
• You should continue to monitor the use of the BWV system as a whole to see if it is still achieving its original purpose. If it appears that it is no longer achieving this purpose or it is no longer required, you should look at potentially less privacy intrusive methods to address the need.
• If you are regularly going to share recorded information with third parties then it is important that you have a data sharing agreement in place with them.

We didn't pursue use which had been requested by a patrol


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