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CCTV User Group Respond to ANPR Proposals

Comment from the CCTV User Group


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.”

88 views2 comments


Unknown member
Aug 05, 2022

Hi Peter, Ilker, I read with great interest your comments on behalf of us all on the ANPR data issue and felt there was another point of view worth airing.

Your statement that you find it shocking when the MPS state there is little expectation of privacy when driving cars, then conflating this with intrusive surveillance, is a little bewildering.

The Service I work for operates an ANPR system in partnership with the MPS. It's a legacy system using analogue cameras, not more modern digital equipment, and like TfL's system it records a plate patch image and an overview image.

The Home Office 'Covert Surveillance and Property Interference code of practice' states:

"3.30 Intrusive surveillance may take place by means…

Unknown member
Aug 10, 2022
Replying to

Hi Andy,

Many thanks for taking the time to construct such an extensive & detailed response.

The views expressed in the Pro Secure News Online article are credited to me and our Vice Chairman and are not represented as the views of every member. There will be times when a healthy exchange of views doesn't always end in agreement. There is no expectation that all our members will always agree.

If the comments in the article are considered by some to be pejorative, that was not the intention. Of course, we wholly support law enforcement having the tools they need to reduce crime and prosecute offenders.

You will see that the statement made in the article by me is conditional…

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