Ashford Privacy Impact Assessment

Project name: Ashford Public Space CCTV
Author: Alison Oates
Approver: Jo Fox

Overview

Using CCTV can be intrusive on an individual's privacy, because it is capable of putting law abiding people under surveillance and recording their movements as they go about their day to day lawful activities. 

Careful consideration should be taken on whether to use it, or not; the fact that it is possible, affordable and has public support should not be the primary motivating factor.

The local authority must consider the benefits that can be gained and take into account what effect it may have on individuals. Ashford Borough Council consider these matters as part of an assessment on the scheme's impact on people's privacy. 

Privacy Impact Assessment (PIA) Screening

The questions below are intended to help to decide whether a PIA is required and, if so, at what level. If the answer is yes to any of the following questions then a PIA is to be completed. 

Screening

Question	Answer
Will the project involve the collection of new data about individuals?	Yes – images will be recorded to the unit hard drive 24 hours a day. However, the data will only be downloaded in compliance with the Ashford Borough Council CCTV Code of Practice. All data is overwritten after 31 days
Will the project compel individuals to provide data about themselves?	No
Will data about individuals be disclosed to other organisations not previously privy to the data?	No – access to the data is to support the purpose of the system as laid down in the Ashford Borough Council CCTV Codes of Practice. Requests for data may be made under the Data Protection Act sections 7 (individuals – subject access), 29 (law enforcement – crime) and 35 (legal proceedings)
Will data about the individuals be used for purposes it is not currently used for?	No
Does the project involve new technology that might be perceived as being privacy intrusive?	No – all cameras are overt and have appropriate signage
Will the project result in making decisions or taking action against individuals in ways which could have a significant impact on them?	Yes – data/images may be provided to law enforcement agencies in relation to the purposes of detection of crime and the apprehension and prosecution of offenders in accordance with the Data Protection Act
Is the data about individuals of a kind particularly likely to raise concerns e.g. health records and criminal records which may be considered private?	No
Will the project require contact to individuals in ways they may find intrusive?	No

Privacy Impact Assessment

Privacy Impact Assessment Need	With the use of overt CCTV cameras, individuals may express concerns as to the privacy whilst spending time in the borough. This assessment is aimed at reducing fear and addressing any privacy issues to limit the perceived impact on general privacy issues
Information flow	Each camera sends images to the monitoring centre Images will be retained for a period of no longer than 31 days as per Ashford Borough Council CCTV Codes of Practice. After that time, unless a specific written request has been made, the system will overwrite the images on a rolling basis Any request for footage will be in accordance with the Ashford Borough Council CCTV Codes of Practice If required for any investigation, images will be retained in line with the Ashford Borough Council CCTV Codes of Practice No images will be reviewed or released outside of the Codes of Practice All CCTV operators hold a valid SIA CCTV licence
Consultation	The following stakeholders were consulted: Police

Risk analysis

Risk	Action	Evaluation
Directed or intrusive surveillance	Ashford Borough Council would only allow directed or intrusive surveillance with the appropriate authorities in place	Low risk, all CCTV staff aware of risk to individual licence and disciplinary procedures should a breach of procedures occur
General individual activity	Cameras will be used in general area view, day-to-day activities not affected	Low risk, operators will conduct camera patrols at regular intervals and carry out a general review of the area. The camera will then be set back to home view
Signage	CCTV information signs are in place where public space CCTV monitoring is taking place. This details that CCTV is operating in the area and information details	Low risk, appropriate signage as per Ashford Borough Council CCTV Codes of Practice
Directed surveillance	Ashford Borough Council CCTV Codes of Practice only allows directed surveillance unless monitoring criminal activity, ASB or events likely to cause harm or distress to others	Low risk, cameras will be operated as per Ashford Borough Council CCTV Codes of Practice

Assessment carried out by

Name: Alison Oates Date: 2 June 2017

Approved by

Name: Jo Fox Date: 8 June 2017