<redacted>
Metropolitan Police Service
Fourth Annual Report to the Home Secretary
on the Operation of the Data Protection
Certificate relating to ANPR Data
For the period November 21st 2010 to December 31st 2011
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<redacted>
1.
Background
1.1
In 2004 the Metropolitan Police Service (the
MPS) and Transport for
London (
TfL) agreed that it
was in the public interest and within their respective powers for
TfL to transfer to the MPS Automatic
Number Plate Recognition (
ANPR) data collected by traffic management and congestion charge
cameras managed by TfL (the
Cameras) solely for
the purposes of safeguarding national security.
1.2
It was agreed by the MPS and TfL that the ANPR data collected by the Cameras (the
ANPR Data)
could only be transferred by TfL to the MPS if the exemption offered by Section 28 of the Data
Protection Act 1998 (the
DPA) could be utilised by both the MPS and TfL. It was subsequently
agreed by both the MPS and TfL that the exemption under Section 28 of the DPA would apply. The
MPS recognised the advantages of having a certificate confirming that the exemption was necessary
for the purposes of safeguarding national security. It was the opinion of TfL that it would not be
acting reasonably if it made such a transfer without a confirmatory certificate made by a member of
the Cabinet under Section 28 of the DPA being in place. The MPS accepted TfL's position.
1.3
The MPS applied to the Secretary of State for the Home Department (the
Home Secretary) for a
certificate under Section 28 of the DPA.
1.4
On 4 July 2007 the Home Secretary signed a certificate under Section 28 of the DPA
providing
conclusive evidence that exemption from
certain provisions of the DPA was required for the purpose
of safeguarding national security in relation to the transfer of the ANPR Data to the MPS by TfL (the
Certificate). On 16th July 2011 the Home Secretary signed an amended certificate that provided
DPA exemption in relation to the transfer of ANPR data from other TfL traffic enforcement cameras
outside of the Congestion Charge Zone (
CCZ); for example Low Emission Zone (
LEZ) enforcement
cameras.
1.5
Under the terms of the Certificate the Commissioner of Police of the Metropolis (the
Police
Commissioner) is required to make an annual report to:
1.5.1
the Home Secretary on the operation of the Certificate; and
1.5.2
the Information Commissioner on the general operation of the Certificate.
1.6
This is now the fourth Annual Report submitted to the Home Secretary. Reports to the Information
Commissioner and TfL were also provided in accordance with the requirements of the Certificate in
the case of the Information Commissioner and the contract between the Police Commissioner and TfL
in respect of TfL.
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Annual Reporting Requirements
2.1
It has been agreed between the Home Office and the MPS that I will report on the following issues as
part of this Annual Report:
Analysis of Personal Data;
Summary of Use;
Difficulties;
Technical Difficulties;
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<redacted>
Challenges;
Transfers;
Requests;
General Privacy Issues;
Usefulness; and
TfL.
2.2
I also comment on steps taken to simplify and harmonise the timing of future reporting and audit.
2.3
The remainder of this Annual Report provides the information relating to each of the above sections.
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Analysis of Personal Data and Clarifying the Reporting/Audit Period
3.1
ANPR Data is collected by TfL <redacted > the MPS <redacted > interrogate the ANPR Data
(the
System).
3.2
<redacted >
3.3
This fourth Report and associated audit covers the period from <redacted >
November 2010 until 31st December 2011. All subsequent reports concerning the analysis of personal
data will cover the calendar year, and this will enable comparison with other relevant and annually
measured data. TfL are in agreement with this change, of which notice was first given in the third
Annual Report.
3.4
<redacted >
3.5
<redacted >
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Summary of Use
4.1
As required by the Certificate the ANPR data has only been processed for the purposes of
safeguarding national security.
4.2
The ANPR Data has been processed for the following purposes:
4.2.1 To assist in intelligence research.
4.2.2 To support national security investigations.
4.2.3 <redacted >
4.3
The majority of the searching on the System has been used to identify the movement
<redacted> of vehicles <redacted> of interest related to national security investigations.
<redacted>
4.4
<redacted>
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4.5
<redacted>
4.6
<redacted>
4.7
<redacted>
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Audit
5.1
The audit of the system, conducted by the MPS Directorate of Information (
DOI) - Information
Assurance Unit - took place after the end of the reporting period and established that:
5.1.1
<redacted>
<redacted>
5.1.2
<redacted>
<redacted>
5.1.3
<redacted>
<redacted>
5.1.4
<redacted>
5.1.5
<redacted>
5.1.6
<redacted>
5.1.7
<redacted>
5.1.8
<redacted>
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<redacted>
6.1
<redacted>
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<redacted>
7.1 <redacted>
7.2 <redacted>
7.3
<redacted>
4
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7.4
<redacted>
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Challenges
8.1
No new challenges of any kind have been made.
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Transfers
9.1
<redacted>
9.2
<redacted>
10
Requests
10.1
As of the date of this report no requests have been made for the ANPR Data by data subjects. Due to
the amount of personal data held by the MPS, the MPS requires all personal data requests to be
specific and general requests for all data are not considered to be valid requests.
10.2
If specific information is requested in relation to ANPR Data the MPS will review the request and, if
possible, provide a specific response. However, if the MPS believes that providing a response in
relation to the question may prejudice the national security of the UK or its allies it may limit any
response to confirming that if a person has driven a vehicle in central London, of which they are the
registered keeper, then their personal data will be processed by the MPS for the purposes of the
safeguarding of national security.
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General Privacy issues
11.1
No complaints about the use of the ANPR Data under the terms of the Certificate have been raised
with the MPS.
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<redacted>
12.1
<redacted>
12.2
<redacted>
12.3
<redacted>
12.4
<redacted>
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TfL
13.1
TfL has been of
great assistance to the MPS in:
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<redacted>
13.1.1 <redacted>
13.1.2 <redacted>
13.2
TfL has been shown a copy of this Report and endorses the content where relevant to that
organisation.
Certification
I certify that this is the fourth annual report for the Home Secretary on the operation of the Certificate as
outlined above, in respect of the period from 21st November 2010 to 31st December 2011.
<redacted
>
Date:
<redacted>
- Appendix A -
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<redacted>
The System Operating Procedures have now been collated into one reference document and available for
inspection within the ANPR Bureau offices.
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