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CCTV User Group Respond to ANPR Proposals


Comment from the CCTV User Group

Background

The TfL Congestion Charge Zone (CCZ) cameras are required to capture a colour image of the vehicle in addition to the number plate data to ensure that the captured number plate is indeed related to that specific vehicle make, model type and colour.


Furthermore, TfL congestion charge zone cameras are used to issue a Penalty Charge Notice (PCN) as a sanction should the congestion charge fail to be paid, so a full colour image of the vehicle is required as this is a legal matter for the registered keeper.


We find the statement by the Metropolitan Police that there is 'little expectation of privacy when driving their cars' rather shocking. Despite being in a public place there are laws that under normal circumstances prevent surveillance using CCTV through the windows of vehicles.


Furthermore, in relation to the statement about the quality of the images taken by ANPR cameras being 'of low quality and unlikely to identify an occupant of a vehicle', if this is the case, how much use can this enhanced contextual data be to police as poor-quality images cannot be used in police investigations as they are of little use in identifying an individual.


In addition, the Greater London Authority (GLA) and TfL are subject to the regulations and guidelines concerning the use of video surveillance systems including ANPR and AI per the Data Protection Act (DPA/UK), GDPR, Protection of Freedoms Act (PoFA) and the Biometrics and Surveillance Camera Commissioner (BSCC) Surveillance Camera Code of Practice.


Peter Webster, Director, CCTV User Group said:

“It is our view the use of ANPR contextual data by police seems excessive unless the request and use of the requested data has been approved by a very senior police officer for a specific purpose and for a specified time period, and only when requested as part of a specific investigation.”


Ilker Dervish, Vice Chairman of the CCTV User Group, said:

“As this proposal can be considered as intrusive surveillance, the GLA should be consulting with the ICO and Biometrics and Surveillance Camera Commissioner to ensure that the basis for sharing such data is legal, ethical and proportionate so that appropriate transparent safeguards can be implemented.”


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