Privacy Notice - Use of Body Worn Video (BWV) Cameras by Parking Civil Enforcement Officers
Background
Test Valley Borough Council’s Civil Enforcement Officers (CEOs) play a vital part in keeping traffic flowing safely and the transport network at its most efficient for all motorists, as well as helping pedestrians get around safely.
To help ensure the health, safety and welfare of our CEOs when patrolling both on and off street parking restrictions, Test Valley Borough Council have made the decision to equip our enforcement officers with Body Worn Video Cameras.
Summary
From April 2019, the Council’s Civil Enforcement Officers (CEOs) will be using Body Worn Cameras, to reduce the risk of verbal and physical aggression towards them. Cameras will only be activated when the CEO considers they are in a situation where they are, or feel they are likely to be, subjected to verbal or physical abuse. Recordings will not be made routinely, or to capture evidence of parking contraventions.
The cameras have a “pre-record” function, so that when activated, the camera will record the incident, and preserve the last minute of video before activation. Following activation, data is encrypted on the camera and retained for 2 months (unless required to respond to a subject access request or for evidential purposes). No other data is retained.
Access to recordings is limited to authorised officers, and the police for law enforcement purposes.
Why have BWV Cameras been deployed?
Over the last few years, and in particular during 2017, the Council noted a significant increase in the number of incidents of both verbal and physical aggression towards our CEOs. This included 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.
Test Valley Borough Council and one other Authority were the only two local authorities in Hampshire who didn’t 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 used the cameras supports the view that the use of Body Worn Cameras has a significant impact in reducing abuse and aggression.
What steps have the Council taken in consideration of the impact on the privacy of the public by using these cameras?
A privacy impact assessment was undertaken to consider the impact upon individuals and their privacy, and to consider measures which could be put in place to mitigate any effect on individuals and their privacy. A copy of the assessment can be viewed here (docx, 853kb)
A public consultation was carried out in May 2018 to seek the views of the public about use of the cameras, so that any concerns could be considered and addressed. Consultation was also been carried out with other Council Officers and Members before a decision was reached to deploy the cameras.
The Council has implemented a policy and procedures which endeavour to mitigate any privacy issues and to ensure the Council’s compliance with the Information Commissioner’s Office (ICO) “Data Protection code of practice for surveillance cameras and personal information”. A copy of the ICO code can be found here
From April 2019 Test Valley Borough Council’s Parking CEOs will be equipped with these recording devices.
When and where will the cameras be used?
The record button on the cameras will only be activated where an 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.
There is a ‘pre-record’ function on the cameras which means that when the parking enforcement officers are carrying out their duties, the cameras will be continually background recording on a ‘loop’, for one minute at a time. This ‘one minute mini-recording’ is then ‘recorded-over’ by a new one-minute recording, and this process continues over and over again throughout the day.
The most recent one minute of ‘pre-record’ footage is only retained on the device if the enforcement officer activates the record button on the device. Then the camera captures and retains that preceding one minute of footage with the recording of the incident.
Unless the record button gets activated, the one minute of pre-record footage is automatically deleted when the camera is turned off.
This ‘pre-record’ feature should help to establish/clarify what has led to the record function being activated.
Recordings will not be made of general patrolling duties or to capture evidence of parking contraventions.
The devices will only be used in a public place.
The devices will record both Audio and Visual. This is to provide a reliable record of what was said in an incident as it may be used as evidence in an internal or external investigation.
How will I know when recording is taking place?
The cameras are worn overtly on the outside of the Officer’s uniform, normally on the chest or shoulder, and the visual display on the camera will clearly show when recording is taking place. When the record button is first activated, the camera also emits a loud high-pitched sound.
Officers should also advise the member of the public where possible that they have commenced recording when they first activate the device.
How will this recorded data be kept secure?
All recordings will be securely held in accordance with agreed data protection procedures. The cameras will encrypt all recordings so that there can be no unauthorised access to any data recorded. Access to recordings will be restricted only to authorised personnel.
How long will these recordings be retained?
Recordings would be deleted after 2 months unless retention is required as part of a subject access request (SAR), or an internal or police investigation, in which case the recording will be retained securely until the investigation or SAR is completed.
Who can access these recordings?
Authorised Council Officers will be able to view the recordings for CEO training and development purposes, to identify areas for improvement when dealing with conflict. Authorised Council Officers will also be able to view the recordings to support an internal Council investigation.
Statutory Prosecution Agencies such as the police will be able to view the recordings for law enforcement purposes, and recorded data may be released to them for evidential purposes for example to support a prosecution.
Data subjects (the person who has been recorded) can request to view the recording in the Council’s Beech Hurst Offices in Andover. Requests must be made via a subject access request. Click here for details of how to make a subject access request.
Who do I contact if I have any queries or complaints about use of the body worn video cameras?
For queries, please contact the Senior Parking Officer Mrs Askew on Telephone 01264 368725, or email carparks@testvalley.gov.uk
If you wish to make a formal complaint you can write to, telephone 01264 368000, email complaints@testvalley.gov.uk or visit the Council offices at:
Beech Hurst, Weyhill Road, Andover, SP10 3AJ or Former Magistrates' Court, Romsey, SO51 8AQ.
Concerns about data protection compliance should be directed to the Information Commissioners Office at www.ico.org.uk