A40 average speed camera trial - governance and use of data arising
william perrin made this Freedom of Information request to Transport for London This request has been closed to new correspondence. Contact us if you think it should be reopened.
Dear Transport for London,
This is a request for information TfL holds in its records concerning the governance and use of data generated by the average speed camera trials on the A40. I presume this has generic applicability to the other averaging camera trial sites.
I welcome measures to improve road safety, am a regular car driver on the A40 and have been familiar with average speed cameras since one of the first national installations on the A43 in Northampton a decade ago.
Neither TfL’s announcement of September 2014
https://tfl.gov.uk/info-for/media/press-...
nor the paper presented to the Finance and Policy committee on 27 November 2013
https://tfl.gov.uk/cdn/static/cms/docume...
mentioned the governance and use of the data generated by these trials.
The nature of digital averaging cameras as opposed to wet film cameras is such that they require data capture about a vehicle when it enters and exits the averaging zone. Data about potential offenders (and possibly others, see below) is then processed largely automatically. Good governance arrangements can mitigate privacy issues. The scale of vehicle movement on the A40 is very substantial. This trial could lead to large quantities of data being captured and processed about people's journeys on a scale such that it is strongly in the public interest for TfL to be transparent about how the data will be managed. Transparency about governance arrangements will increase public confidence in the system
This is a request under the FOIA and the EIR for information you might hold on the following in respect of the A40 average speed camera trial and the averaging camera trials more generally:
Who will operate the cameras (including sub contractors)?
Who will store the data?
Where will the data be stored?
Who will the data be shared with?
What governance arrangements are in place for the data and which people are involved in them? For instance is there a committee that governs the data system? Who sits on it, their role etc?
How many data points are estimated to be recorded per day?
What happens to data recorded that does not lead to an investigation (ie people whose data is captured for the purposes of averaging and are not breaking the speed limit)?
Is any data at all used by the authorities under any circumstances for any non-speeding related activities – such as, but not exclusively the prevention of crime, tracking vehicles ‘of interest’, spotting stolen cars, uninsured cars, un taxed cars, TfL buses, traffic flow statistics?
What is TfL’s data retention (and deletion) policy?
At what point is the data held matched against DVLA records to produce a vehicle owner identity of a natural person? How is this data about people held, what TfL policies apply to it?
What is TfL's anonymisation policy?
What is TfL’s data access policy when in receipt of a request from the law enforcement community?
What are the speeding trigger/tripping points for the system on the cameras – ie at what speed level are they set/what is the margin for error?
Any forecasts that may exist of the level of offences/ticketing
Will any of the outputs of the trial be released as open data - such as flow rates?
Any correspondence with the Information Commissioners Office and the system design and governance
Should be able to answer this request in part, not in full, then please do so rather than rejecting the whole request.
I prefer to receive information by electronic means through this service.
If you require any clarification or wish to ask any questions to fulfill your obligations in law then please contact me through this service.
The scale of the trials is substantial involving hundreds of thousands, possibly millions of people and as such there is a strong public interest in making this information available.
I have also requested separately information about the structure of these trials see https://www.whatdotheyknow.com/request/a...
Yours faithfully,
wiliam perrin
william perrin left an annotation ()
I have also asked the ploice chiefs for some information on governance of ANPR in general
https://www.whatdotheyknow.com/request/a...
william perrin left an annotation ()
There is also a report that describes more about the ANPR system, (of which the A40 trial will no doubt form a part) albeit from the perspective of an anti cctv lobby group here
http://www.no-cctv.org.uk/docs/Whats%20W...
Dear Mr Perrin
TfL Ref: FOI-0999-1516
Thank you for your email received by Transport for London (TfL) on 2 September 2015. Your request will be processed in accordance with the requirements of the Freedom of Information Act and TfL’s information access policy.
A response will be provided to you by 30 September 2015. We publish a substantial range of information on our website on subjects including operational performance, contracts, expenditure, journey data, governance and our financial performance. This includes data which is frequently asked for in FOI requests or other public queries. Please check http://www.tfl.gov.uk/corporate/transpar... to see if this helps you.
In the meantime, if you would like to discuss this matter further, please do not hesitate to contact me.
Yours sincerely
Ida Harris | FOI Case Officer
FOI Case Management Team
Transport for London
william perrin left an annotation ()
TfL have responded to another FOI request to say the A40 averaging speed cameras will go live around the end of October 2015 see https://www.whatdotheyknow.com/request/a...
william perrin left an annotation ()
I have used the ICO's 'raise a concern' process to see if they can help expedite this issue. My covering email to the forms is below
>Hello
I spoke to your telephone line - they suggested i mark this as urgent. At the end of October, TFL will start a large trial involving huge quantities of personal movement data and are not responding promptly to my FOI requests about the nature of the trial nor what happens to the data arising. I have consulted with the CFOI who are as puzzled as I am.
The trial is due to start at the end of October, TfL are pleading S17 until 26 October.
This does not allow sufficient time for the traditional internal review and appeal route before this trial commences.
I should be grateful if you could expedite this with TfL
Details in attached.
Yours
William Perrin
Dear Mr Perrin
TfL Ref: FOI-0999-1516
Thank you for your email received by us on 2 September 2015 asking for
information about average speed cameras on the A40.
Your request has been considered in accordance with the requirements of
the Freedom of Information Act and our information access policy. You
asked for:
Who will operate the cameras (including sub contractors)?
The cameras are maintained by Siemens plc on behalf of Transport for
London (TfL) and the Metropolitan Police Service (MPS).
Who will store the data?
Siemens store the data in an encrypted format. Data relating to a speeding
offence is shared with the Metropolitan Police who then become the Data
Controller for that information.
Where will the data be stored?
The data will be stored on DVD in an encrypted format by Siemens. The MPS
are responsible for the storage of data that is provided to them.
Who will the data be shared with?
TfL’s subcontractor Siemens supplies the data directly and solely to the
MPS.
What governance arrangements are in place for the data and which people
are involved in them? For instance is there a committee that governs the
data system? Who sits on it, their role etc?
The processing of the data by the Metropolitan Police is a matter for the
Metropolitan Police. We do not hold details of the Metropolitan Police
data governance arrangements at this level.
How many data points are estimated to be recorded per day?
This information is not held by TfL. This information would be held by the
MPS.
What happens to data recorded that does not lead to an investigation (ie
people whose data is captured for the purposes of averaging and are not
breaking the speed limit)?
The system only creates a record when an offence is detected, so there is
no retention of data where no offence is detected.
Is any data at all used by the authorities under any circumstances for any
non-speeding related activities – such as, but not exclusively the
prevention of crime, tracking vehicles ‘of interest’, spotting stolen
cars, uninsured cars, un taxed cars, TfL buses, traffic flow statistics?
The information is collected and sent to the MPS for the enforcement of
the speed limit. TfL do not receive or make use of any data from the
cameras.
What is TfL’s data retention (and deletion) policy?
TfL has no specific data retention and deletion policy in relation to data
from the average speed cameras for the reasons outlined above.
TfL’s overall approach to data retention and deletion is contained within
our Information and Record Management Policy (IRM) . TfL has a range of
corporate and local disposal schedules which contain the
retention/disposal rules for various types of data. In deciding the
appropriate retention periods for data, we take into account the
requirements of the Data Protection Act (in the case of personal data), as
well as the legitimate needs of the business and any legal or regulatory
requirements that might be in place. For your information, I have also
attached the Information Record Management (IRM) policy.
At what point is the data held matched against DVLA records to produce a
vehicle owner identity of a natural person? How is this data about people
held, what TfL policies apply to it?
The MPS are the data controller for processing this. The requested
information is not held by TfL.
What is TfL's anonymisation policy?
TfL has no anonymisation policy in relation to data from the average speed
cameras for the reasons outlined above.
TfL does not currently have a formal business-wide anonymisation policy.
There are local rules in place for various different types of personal
data; for example Oyster journey data is retained for period of eight
weeks before it is anonymised. We provide information to the general
public via our website about how long TfL keeps personal data before it is
either deleted or anonymised: [1]www.tfl.gov.uk/privacy . However, TfL
also adheres to the statutory Code of Practice on Anonymisation published
by the Information Commissioner’s Office (ICO).
What is TfL’s data access policy when in receipt of a request from the law
enforcement community?
TfL has a formal policy covering data disclosures to the police and other
statutory law enforcement authorities. Please see attached. In some
circumstances, disclosures of personal data to the police (and other law
enforcement agencies) are permitted by the Data Protection Act 1998 (DPA),
if they relate to the prevention or detection of crime and/or the
apprehension or prosecution of offenders. Before any such disclosure takes
place, the police are required to demonstrate that the personal data
concerned will assist them in this respect. Each police request to TfL is
dealt with on a strict case-by-case basis to ensure that any such
disclosure is lawful and in accordance with the DPA.
Any correspondence with the Information Commissioners Office and the
system design and governance
To date, TfL has not corresponded with the Information Commissioner’s
Office on the specific design and governance of the average speed camera
trial.
What are the speeding trigger/tripping points for the system on the
cameras – ie at what speed level are they set/what is the margin for
error?
This information is not held by TfL. The equipment is a Home Office Type
Approved device.
Any forecasts that may exist of the level of offences/ticketing Will any
of the outputs of the trial be released as open data - such as flow rates?
TfL and the MPS do not forecast the level of offences. At the time of your
request there was no intention to publish information from the average
speed enforcement trial. However, both the Metropolitan Police and TfL are
subject to the Freedom of Information Act and any request which results in
the release of a dataset will place a requirement on the relevant public
authority to consider publication of the dataset.
If this is not the information you are looking for, or if you are unable
to access it for any reason, please do not hesitate to contact me.
Please see the attached information sheet for details of your right to
appeal as well as information on copyright and what to do if you would
like to re-use any of the information we have disclosed.
Yours sincerely
Ida Harris | FOI Case Officer
FOI Case Management Team
Transport for London
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william perrin left an annotation ()
As well as the request above and the request linked to about the trials I have put in a request to the LB Ealing through which the trial area largely runs (please let me know if I have my geography wrong) see
https://www.whatdotheyknow.com/request/a...
My interest in the A40 speed cameras isn't a petrol-head one - i have a long track record in campaigning for cycle safety in London and for speed limits in Northampton - but is a desire to see effective civilian involvement in the governance of large police databases see:
http://talkaboutlocal.org.uk/police-data...