Buckinghamshire County Council Transport for Buckinghamshire ANPR Code of Practice 1 Introduction 1.1 Buckinghamshire County Council (BCC) Transportation Service has Automatic Number Plate Recognition ('ANPR') cameras on a number of significant and important roads in the county. This is to enable journey times to be monitored, for the purposes of reducing congestion. 1.2 Legitimate concerns exist over the use of ANPR. To maintain general confidence, it is necessary to respect individual privacy and ensure adequate control and supervision of these systems, together with scrutiny of their operation. 1.3 Although not the primary purpose of the system, ANPR will occasionally be processing personal data. As a user of ANPR, BCC has an obligation to comply with the provisions of the Data Protection Act (DPA) 1998, when the systems require the processing of personal data. For the purposes of the Data Protection Act the data controller is Buckinghamshire County Council. A privacy impact assessment (PIA) has been undertaken as recommended by the Information Commissioner and is included with these documents. 1.4 This code of practice and the appendices are based on the Information Commissioner's CCTV Code of Practice for the users of CCTV and similar surveillance equipment such as ANPR that monitors spaces to which the public have access. 1.5 The purpose of this code of practice is to establish: the purpose of the scheme responsibility for the scheme, including the day-to-day management security and disclosure procedures 1.6 The code of practice and the appendices aim to aid users of ANPR systems in meeting their legal obligations. Compliance may be a consideration in the determination by the Information Commissioner as to whether the County Council has made proper use of ANPR. Therefore, the County Council will review compliance with the policy requirements on a periodic basis. 1.7 BCC will share our ANPR equipment with Thames Valley Police (TVP), who will reciprocate by permitting us to access their ANPR cameras. This is to reduce the need for multiple cameras to be installed in similar locations. This results in reduced street clutter, reduced costs, improved efficiency as well as contributing to the shared Buckinghamshire Sustainable Community Strategy Theme of having Safe Communities. 2 Purposes of the ANPR System 2.1 ANPR monitoring systems will be a part of a wider data collection programme designed to monitor congestion on strategic routes in the county where fluctuating traffic conditions, or increased pressures, required traffic 1
management to be implemented. This information will then enable us to supervise and manage the free flow of traffic, and support the planning of future improvements to the highway network. 2.2 BCC will operate the ANPR to monitor and track journey time reliability on some of the key routes in Buckinghamshire. 2.3 The objectives of the ANPR system are: to manage an efficient transport network; crucial for a successful economy to enable BCC Transportation Service staff to monitor and react to traffic conditions, congestion and incidents to provide information helping to produce a town wide view of traffic conditions, and inform future highway network planning and improvements. to provide and operate the system in a manner that is consistent with respect for individual privacy 2.4 Any change to these objectives will need to be approved by the Head of Transportation, who will need to ensure compliance with necessary legislation, and seek legal and data protection guidance where necessary. The Head of Transportation will also need to assess whether any further Member approval or public consultation is required. 2.5 Any requests for information identifying people from individuals or organisations will be routed through the County Data Protection Officer for consideration 3 Use of ANPR 3.1 BCC ANPR cameras will transmit 2 separate feeds of Data. One will be sent to BCC and one will be sent to TVP. Access and use of the system in the control room will be in accordance with the accompanying Appendix A on the Administration of the Control Room. 3.2 BCC will not receive any vehicle image data from the ANPR cameras. BCC will only receive the depersonalised Vehicle Registration Number (VRN) of each vehicle that passes through a camera. This data will be automatically processed by software to provide average journey time information to the control room operatives.. 3.3 To ensure anonymity all VRN information will be depersonalised in accordance with the national UTMC protocol. 3.4 BCC will ensure the public is made aware of the presence of the system and its ownership by signage in the camera localities. This signage will clearly state the ownership of the system, its primary purpose as a traffic 2
management tool, that no sound is recorded, where further information can be found on the system via website and contact details, the partners we share the equipment with, and the contact details for these. See Appendix D for the signage to be used. Any temporary of mobile installation will require the same levels of signage, as a permanent installation. 3.5 TVP will have access to ANPR information directly fed into their network. BCC will not have any access to this information. TVP may collect images and full VRN data but will do so in accordance with their current policies. 3.6 No raw data collected from the ANPR system will be used for any commercial purpose, although derived data on journey time information could be following agreement by the Head of Transportation. 3.7 There is currently no sound recording from any part of the ANPR camera system. 3.8 The use of and access to our ANPR equipment by TVP will be subject to the terms of their own policies and operating procedures, and accord with an agreed memorandum of understanding. 3.9 Materials obtained from the BCC ANPR equipment may be released to the media by TVP, if agreed in advance with the BCC Head of Transportation. 4 Managerial Responsibility 4.1 The ANPR installation is entirely owned by the County Council. The Head of Transportation has strategic managerial responsibility for the ANPR scheme. 4.2 Operational management and maintenance responsibility lies with the Intelligent Transport Systems Team Leader. 4.3 The Intelligent Transport Systems Team Leader is to ensure: the ANPR is operated in accordance with this code of practice and the accompanying appendices the operating procedures for the scheme have been complied with the purposes and objectives of the scheme are not exceeded the regular (at least annually) evaluation of the usage of the system is carried out, as well as its compliance with any new legislation, guidance, codes of practice or good practice. A report on this evaluation should be submitted to the BCC Information Governance Board and be publically available. 3
persons entering a public area covered by the ANPR system are made aware that an ANPR scheme is in operation the system is operational for twenty-four hours a day throughout the year. Details of the location of all the cameras owned by BCC are available to the public at all times 4
4.4 The Chief Executive of the County Council is responsible for ensuring the Authority is compliant with the requirements of the Data Protection Act 1998 and for providing advice to County Council employees. 5 Access by Individual Data Subjects 5.1 Whilst information collected as part of ANPR will not include the retention of images any requests by individual data subjects for disclosure of images or data relating to them should be submitted to the County Council, initially through the Council s Data Protection Officer. 5.2 If approved, the Intelligent Transport Systems Team Member is responsible for meeting the request to provide the data if available. 5.3 All requests will be recorded, and records maintained, for a period of no less than 3 years. Where the request is denied, the reason will also be documented and any legal exemption used recorded. 6 Access to and disclosure of images to third parties 6.1 There will normally be no disclosure of recorded images to third parties other than regulatory bodies and the data subjects themselves. Where disclosure is made, it will be because the images would assist in a specific criminal enquiry, or to identify a victim, witness or perpetrator in relation to a criminal incident. Disclosures may also be made to third parties to facilitate the well being of vulnerable individuals. 6.2 All requests for access or disclosure should be made in writing to the County Council, and processed in accordance with our procedures. 6.3 All requests will be recorded, and records maintained for a period of no less than 3 years. Where the request is denied, the reason will also be documented and any legal exemption used recorded. 7 Monitoring Compliance and Complaints Procedure 7.1 There is recognition that staff, Council members, visitors, and the public may have matters of concern in respect of ANPR operations. 7.2 Any individual who wishes to express a concern or make a complaint in respect of ANPR operations or compliance should address those in the first instance to the Head of Transportation. Details of our complaints procedure will be available on our website. 8 Media Enquiries 8.1 Any enquiries from the media about the use of ANPR should be referred to the County Council Central Communications Team. 9 Supporting Documentation 9.1 This code of practice is supported by the attached appendices on: 5
Administration of the Control Room Managing Requests from Outside the County Council for ANPR Data Siting of ANPR Cameras BCC Transportation ANPR Signage Privacy Impact Assessment 9.2 This Code of Practice and its appendices will be reviewed annually. Updates or revisions will be made as required. 10 Breaches of the Policy and Code (including breaches of security) 10.1 BCC Control Room Staff will have primary responsibility for ensuring that there is no breach of security and that this Code is complied with. The staff will have day to day responsibility for the management of the Control Room and for enforcing this Code. Non-compliance with this Code by any person will be considered a severe breach of conduct and will be dealt with accordingly, including, if appropriate, by criminal proceedings. 6