SCC Codes of Practice Guidelines
Although primarily concerned with video and CCTV cameras and general surveillance of the law-abiding public, UK law restricts the proliferation of public facing cameras primarily through the Protection of Freedoms Act. Any public facing camera (even one only taking stills of offences), falls within the definition of a Surveillance Camera. AutoSpeedWatch concerns itself with vehicles (not identifiable people) but nonetheless the guidelines apply.
Under the Protection of Freedom Act 2012 (PoFA), the Surveillance Camera Commissioner for England and Wales provides statutory oversight of police and local authorities and parish councils (defined as relevant authorities in PoFA). Therefore, as a parish council/local council/local authority installer and operator of a roadside unit you therefore need to be familiar and compliant with the the act and the corresponding Surveillance Camera Commissioner's Codes of Practice.
The Guiding Principles
The Surveillance Camera Codes of Practice has 12 guiding principles. As the installing authority, YOU should be aware of the codes of practice, and ensure you meet them. To help you we've got some initial thoughts (in italics) for you to start with.....
|1||What’s your system for?|
It's for the improvement of community safety through the reduction of excessive speeding, in collaboration with the Police.
|Do you review its use?
You (your council) should regularly review (probably annually) whether the system still needs to be active.
|2||Have you carried out a privacy impact assessment?|
You should assess and document the privacy impact of the placement of a camera. We have designed the unit to try not to record individuals, and only record vehicles. Nonetheless you should review whether there is likely to be privacy impact to others, such as residential windows, pedestrians, play areas, etc.
|Do you publish your privacy impact assessment?
You should document your privacy impact assessment, and make this document publicly available. It needs to refer to each roadside unit installed separately.
|3||Do you have signage in place to say surveillance is taking place?|
You should purchase the AutoSpeedWatch Signs, or ensure you have your own signage with contact details.
|Is there a published point of contact for people to raise queries or complaints with?
The AutoSpeedWatch road signs have contact details and also refer to the local/parish council.
|4||Who’s responsible for your system?|
Your nominated Community SpeedWatch (CSW) coordinator, working under the guidance of the local police force and in conjunction with Autospeedwatch Limited.
|Are your staff aware of their responsibilities?
You should ensure that your councillors and the CSW coordinator are aware of their responsibilities to protect privacy under the Protection of Freedoms Act and are familiar with the Surveillance Camera Codes of Practice.
|5||Do you have clear policies and procedures in place?|
The policies and procedures for the handling and processing of offending vehicle data are usually defined by each police force as part of the CSW scheme. Your CSW coordinator should receive those policies from their local police force and detail them to your council. AutoSpeedWatch provides mechanisms for adherence to typical policies and procedures, and minimises the access to data by restricting users through privileges according to their role. AutoSpeedWatch also has separate policies for the general public and users of the system, as well as internal policies for automated backup, data management, processing, and disposal, and breaches of security.
|Do your staff know what your policies and procedures are?
You will need to inform and maintain the knowledge of those involved in your use of AutoSpeedWatch.
|6||How long do you keep images/information?|
Users of the system are limited to the minimum information required to perform the Community Speedwatch function. All information provided by the system remains the property of Autospeedwatch Limited but is made available to each community and the police according to their access privileges, and is provided by secured account access from our servers based in Maidenhead and Milton Keynes within the UK. None of the offence information stored within the AutoSpeedWatch system directly identifies individuals. Images of vehicles are kept for 12 months before being deleted from the system. Data associated with individual vehicles is kept for up to three years. Meta data of the system is kept indefinitely.
|How do you make sure images/information is deleted once they’re no longer needed?
Scripted automated processes remove information from the secure server when the information is no longer needed.
|7||Do you have a policy on who has access to the stored information?|
AutoSpeedwatch provides access to those that need it only, according to their role privileges. Managers (normally police area managers) can see, edit and delete speeding offence records across all CSW schemes within their area. Coordinators (normally CSW coordinators) can see, edit, report on, and delete speeding offence records across all the roadside units in their own CSW scheme. Validators (normally CSW team members) help the coordinator, by manually checking and validating individual speeding records.
|Do you have a policy on disclosure of information?
This is normally defined by the local police force. AutoSpeedwatch restricts who can see reports on speeding offences to the nominated police or local authority contacts. Terms and Conditions require users not to copy, replicate, or distribute information to others.
|8||Do you follow any recognised operational or technical standards?
As defined by the relevant local police force coordinating the CSW schemes within their area.
|9||Do you make sure that the images captured by your system are caught securely?|
Yes. AutoSpeedWatch captures each recorded offence and sends them across securely encrypted internet links (to banking encryption standards). It does not store the information locally. Only registered users are able to retrieve speeding offence records.
|Are only authorised people given access to the images?
|10||Do you evaluate your system regularly to make sure it’s still required?|
You should review whether AutoSpeedWatch is still required and appropriate from time to time.
|Could there be an alternative solution to a surveillance camera system?
Traditional by-the-roadside Community Speedwatch is an alternative, but has abuse and accident risks, and produces less information for the police to use.
|11||Can the criminal justice system use the images and information produced by your surveillance camera system?|
No. The equipment used is for information only and is not Home Office Type-Approved for the purposes of evidence in a court of law.
|Do you have a policy on data storage, security and deletion?
Each force will have separate requirements for the storage, security, and deletion of information. AutoSpeedWatch Limited deletes information as described above.
|12||Do you use any specialist technology such as ANPR, facial recognition, Body Worn Video (BWV) or remotely operated vehicles (Drones)?|
AutoSpeedWatch is not an ANPR System (a system that automatically reads the licence plates of all vehicles). Such systems are very intrusive. It does, however, offer an optional tool to help validate the licence plate of an offending vehicle (i.e. after an offence has been recorded) as part of the manual validation process. Sometimes this can help speed up the manual record-checking process. It does not increase the amount of intrusion, or the number of records recorded. This tool can be switched on or off by the CSW coordinator as required.
|Do you have a policy in place to ensure that the information contained on your database is accurate and up to date?
Records are individually time-stamped. Aged records are removed according to policy.