Use of Body Worn Video Cameras by Parking Civil Enforcement Officers

Public Consultation – Privacy Impact Assessment


The Department for Infrastructure wants to improve travel for everybody; whether pedestrians, cyclists, bus passengers, car or lorry drivers. Civil Enforcement Officers (CEO’s) play a vital part in keeping traffic flowing safely and the transport network at its most efficient for all motorists. Test Valley Borough Council employs Civil Enforcement Officers to enforce on and off street parking restrictions to meet this objective.

To help ensure the health, safety and welfare of our CEOs when patrolling, Test Valley Borough Council is currently considering equipping our Enforcement Officers with Body Worn Video Cameras.

This document sets out the Council’s proposals, and invites comments from the public. These comments will be taken into account in the preparation of a privacy impact assessment, before a final decision is taken on whether to implement the proposals, when Body Worn Cameras may be used, and how any recordings which are made may be used.


Why are Body Worn Cameras being proposed?

Over the last few years, and in particular during 2017, the Council has noted a significant increase in the number of incidents of both verbal and physical aggression towards our CEOs. This includes verbal intimidation, threats of violence, intimidation and inciting hate against our officers via social media, and physical assaults.

The Council has a responsibility for the health, safety and welfare of its staff. Enforcement Officers already regularly undertake conflict management training to help equip them with the skills needed to effectively manage confrontational situations, but the Council must consider further measures which can protect staff.

Test Valley Borough Council is one of only two local authorities in Hampshire who do not currently provide their CEOs with Body Worn Cameras. Most of the local authorities across the South of England also equip their CEOs with Body Worn Cameras. Evidence from local authorities who use the cameras suggests that the use of such devices has a significant impact in reducing abuse and aggression.


Possible Measures to Reduce Impact on Privacy

The Council has started to consider measures which could be put in place to mitigate any effect on individuals and their privacy. These are set out below. It should be emphasised that the purpose of presenting these measures in this consultation document is to assist and inform the public as part of consultation exercise – a decision on the measures to be implemented will only be taken when the responses to the Consultation have been considered and the Privacy Impact Assessment concluded.


Possible measures could include:

  • All recordings to be encrypted so that there can be no unauthorised access to any data recorded;
  • Cameras to be overt and prominently worn by the CEO (normally on their chest.) When the camera is recording, a clear indication would be visible to the public to show that the camera was in use;
  • The camera would only be activated where the enforcement officer finds themselves in a confrontational situation where they are subject to, or feel they are likely to be subject to, verbal or physical abuse. Recordings will not be made of general patrolling duties or to capture evidence of parking contraventions;
  • All recordings will be securely held in accordance with agreed data protection procedures. Recordings would be deleted after 30 days unless retention is required as part of an internal or police investigation;
  • Access to recordings will be restricted to authorised personnel;
  • The Council will publish strict and clear guidelines relating to who can view any recorded footage and how these requests must be made.


It is proposed that recordings will only be used for the following purposes:

  • Criminal investigations carried out by the Police;
  • Dealing with complaints from the public about the conduct of a Civil Enforcement Officer;
  • Protecting the Health and Safety of Civil Enforcement Officers.



The Information Commissioner’s Office (ICO) has issued a “Data Protection Code of Practice for Surveillance Cameras and Personal Information”, and the Home Office has issued a “Surveillance Camera Code of Practice”. Both of these Codes recommend that a Privacy Impact Assessment is carried out to ensure that the use of the cameras takes into account the effect on individuals and their privacy.

The Council is therefore carrying out a formal consultation exercise to seek views on the use of Body Worn Cameras by our Parking Civil Enforcement Officers, so that they can be taken into account as part of the preparation of our Privacy Impact Assessment.

As well as general comments on the proposal, comments are sought on the measures to could be taken to mitigate the impact on privacy of members of the public, and the use to which the recordings are to be put.

The consultation is now open, and runs until 31 May 2018. Please email any comments to: