PRIVACY IMPACT ASSESSMENT
PRIVACY IMPACT ASSESSMENT
The below form is designed to assist you in carrying out a privacy impact assessment (PIA).
Privacy Impact Assessment screening questions
These questions are intended to help you decide whether a PIA is necessary in the first instance.
Name of Person Responsible
Paul Leonard (Control Room Manager)
Date of Assessment:
8th June 2021
Review Date:
8th July 2022
Camera location (if applicable)
Location 1:
Queen Elizabeth Way/Concorde Way roundabout 1 x PTZ
Location 2:
Ingleby Way 1 x PTZ
Location 3:
Barwick Way 1 x PTZ
Camera Number and type (if
Camera numbers to be assigned.
known)
HikVision
Camera type (PTZ, Static etc.)
Pan, Tilt and Zoom and Static (mix)
Is CCTV system covered by ICO registration number?
Yes
No
If so, please state
Z590889X
Has the Surveil ance Camera Code of Practice self-assessment tool been used
Yes
No
to assist in completion of this PIA?
Wil this proposed installation be part of an existing CCTV system certified to the
Yes
No
Surveil ance Camera Code of Practice?
Checklist
Answering ‘yes’ to any of the following questions is an indication that a PIA would be a useful exercise.
You can expand on your answers as the project develops if you need to.
Introduction of a new surveil ance camera system or additional camera (includes
Yes
No
static cameras) which can collect new personal information about individuals
Changing location and/or field of view of an existing camera
Yes
No
Upgrading cameras which can obtain additional views or enhanced views which
Yes
No
may impact on privacy e.g. HD cameras, IR lighting, more powerful lenses, 360
degree cameras
Introduction of new technology that may affect privacy (e.g. Automatic Number
Yes
No
Plate Recognition, Body Worn Video, Automated Recognition Technology,
Unmanned Aerial systems (Drones) or similar
If so, please state
Using re-deployable cameras (to be completed for every new deployment)
Yes
No
Installation of the camera results in decisions or action against individuals in ways
Yes
No
that can have significant impact on them (this would include, fine, notifying police,
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patching through images of suspects to police control rooms and Regulation of
Investigatory Powers Act 2000 – RIPA)
Is the information collected about individuals of a kind likely to raise privacy
Yes
No
concerns or expectations? For example, criminal records or other information
that people would consider particularly private. (Note: may include radio
transmissions from the CCTV Control room to store watch and pub watch
systems. These regularly mention individuals and their previous convictions
which can be heard by members of the public as well as suspect. The risk
would need to be identified in the PIA and the solutions addressed.)
Introduction of Wi-Fi, microwave, GSM, airwave transmission etc.
Yes
No
(Is it encrypted?)
If so, please state
Dedicated log in and password and dedicated SSID number
Extending periods of recording
Yes
No
Upgrade in recording frames per second (increase in image capture)
Yes
No
Analogue to digital recording
Yes
No
Where other agencies/organisations are involved in activities where there is
Yes
No
potential for privacy to be compromised, e.g. monitoring, handling,
processing, sharing data/images etc.
Any alteration to the way images and data are handled, viewed, processed,
Yes
No
disclosed, shared, disposed, retrieved, accessed, stored
Any other process or use which increases the risk to privacy
Yes
No
If so, please give details
Does the introduction of a camera system or individual camera increase the risks
Yes
No
to the Organisation? E.g. potential non-compliance with data protection or other
legislation, legal actions by individuals, etc.
If you tick ‘YES’ to any of the above, please complete the following PIA. If in doubt it would be advisable
to complete a PIA anyway and inform the system manager of your decision to do so.
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Privacy Impact Assessment
1. Identify the need for a PIA
The following are examples of some of the possible aims of the installation/project. If applicable tick one
or more of the following aims then briefly explain what the benefits wil be to the organisation, individuals
and other parties. If there are other aims please detail and explain.
You can refer to other documentation related to the proposed installation or project e.g. Operational
Requirement, business case, project proposal, feasibility survey etc.
1.1 Aims
a. reducing the fear of crime
b. deterring and preventing crime
c. assisting in the maintenance of public order and reducing offences
d. provide high quality evidence which may assist in the detection of crime and the apprehension
and prosecution of offenders
e. protecting property
f. providing assistance with civil claims
g. providing assistance with issues relating to public safety and health
h. providing assistance and reassurance to the public in emergency situations
i. Assist with traf ic management
j. Recognition of number plates (ANPR)
k. Other, please specify
1.2 Benefits
Having identified the aims please explain the benefits to Stockton Borough Council, to individuals and to
other parties. This could include such things as reduction in crime and offences, reduction in fear of
crime, detection of anti-social behaviour etc. The benefits should be capable of being measured and not
anecdotal (If you have completed an operational requirement (OR), as recommended, in relation to this
PIA please refer to the OR for risk analysis)
The overarching aim of the system is to contributie to making the community of Ingleby Barwick a safer
and more welcoming place to live and visit. The specific benfit of the system is to provide independent
evidence to support a number of legitimate legal aims in support of improving community safety such as
the prevention and detection of both criminal offences and anti-social behaviour in the area.
The secondary aim of the system is to contribute in the overall partnership effort to deny criminals use
of the road network around Stockton on Tees of which Ingleby Barwick has a number of key aertierial
road routes in and out of the area with a large volume of vehicle movements. Finally, the system is
intended to contribute to improving the perception and fear of crime and disorder as well as helping the
council manage the road network efficiently.
Stated Aim - Prevention and Detection of Crime / Reduction of Crime
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In the financial year 2020/2021, a total of 1,959 crimes or reports of anti-social behaviour were recorded
in Ingleby Barwick (Stockton Partnership Strategic Assessment, 2021). This included a total of 161
incidents involving vehicle related issues such as anti-social driving. A further 53 offences related to
theft, with an additional 21 offences relating to vehicle crime and 31 burglaries.
This is an increase of 250 incidents compared to 2019/2020 and 278 incidents compared to 2018/2019
despite a range of multi-agency interventions on the estate including additional partnership patrols and
interventions such as youth engagement / direction, improvement in street lighting and problem solving
work. The area also benefits from additional funding for the Civic Enforcement Service, providing
additional resources for problem solving and responding to key community safety issues. Whilst these
measures have been successful by certain measures, it is clear more needs to be done to positivley
impact on the levels of crime in the area.
By increasing the available network of traditional CCTV cameras, it is expected that the overall level of
recorded crime and anti-social behaviour can be reduced for the benefit of the community similar to that
seen in other parts of the country.
Stated Aim - Deterrence
Local Authorities are also expected to implement new and innovative ways of improving community
safety, such as new technologies. By having an available network of CCTV installed around the
scheme locality, those using the road network for criminal behaviour run the reasonable risk of being
detected in doing so whilst also reducing the privacy impact on those road users going about their
lawful business.
Stated Aim - Improving Perception and Fear of Crime
Whilst significant intervention work and investment has been undertaken in both Stockton on Tees and
indeed Ingleby Barwick in the past decade, crime and anti-social behaviour continues to be a significant
concern for residents. Research has shown that the public perception and fear of crime and disorder
has increased in Stockton and is also the case in Ingleby Barwick. The fear of crime can have a
significant impact on the health and wellbeing both of individuals and of whole communities. Recent
events in Ingleby Barwick which has resulted in media and political coverage have continued to
evidence this strong feeling within the community for new an innovative measures to improve safety are
needed.
A public consultation conducted between February and April 2021, by the Safer Stockton Partnership
(Community Safety Partnership) evidenced clearly that the majority of responders felt that both the
levels of crime and anti-social behaviour had increased within their community despite official recorded
figures showing a reduction in many areas. Furthermore a total of 63% reported feeling less safe in
their community than they did a year ago. Key issues identified included drugs, anti-social behaviour
and burglary as key concerns with more resources and CCTV being a key theme that residents wanted
to see introduces as an intervention.
A total of 27% of the overall responses to the consultation came from residents who provided an
Ingleby Barwick postcode (TS17).
These findings are further supported by the outcome of a MORI survey conducted in 2019. This
conusltation highlighted that people felt signicnatly less safe during the day and night whilst in the
community compared to findings in 2015.
In light of these findings, it is intended that a new and innovative approach to community safety
benefiting from technological advancements in improved CCTV to support the multi-agency partnership,
wil in part help restore confidence and improve perceptions around crime and ASB in the future. This
wil be measured and evidenced by improvements in public consultation outcomes and engagement
with the community specifically through existing methods such as community groups, elected members
and ward surgeries for example.
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1.3 Summarise why the need for a PIA was identified
Completion of the screening questions wil assist in identifying the need for a PIA.
Possible needs might include:
a. Capture of new personal data/images
b. New or additional locations/areas which have potential for privacy implications
c. Use of new technology which is capable of capturing enhanced images e.g. BWV, automated
recognition, 360 degree views, higher powered equipment, etc
d. Surveil ance camera systems with audio recording capability e.g. BWV
e. Alteration to the way images and data are handled, viewed, processed, disclosed, shared,
disposed, retrieved, accessed, stored
f. Use of technology which captures vehicle registration numbers (ANPR)
g. Other, please specify
2. Describe the information flows
You should describe the collection, use and deletion of personal data here and it may also be useful to
refer to a flow diagram or another way of explaining data flows.
2.1 How is information collected?
CCTV camera
BWV
ANPR
Unmanned aerial systems (drones)
Stand-alone cameras
Real time monitoring
Other (please specify)
2.2 Does the systems technology enable recording?
Yes
No
Please state where the recording wil be undertaken (no need to stipulate address just Local Authority
CCTV Control room or on-site would suffice for stand-alone camera or BWV)
The images recorded by the camera wil viewed and stored at an approved Stockton on Tees Borough
Council premise as an addition to the current surveil ance network in place.
Is the recording and associated equipment secure and restricted to authorised person(s)? (Please
specify, e.g. in secure control room accessed restricted to authorised personnel)
The recorded images and associated recording equipment are secure within the control room of the
building. The building housing the control room was originally built utilising the specifications of 'BS
5979 Category 2 - Alarm Receiving Centre British Standards'. The building has an electronic gated
entrance aswell as internal and external CCTV to control access from the site. A 24 hour security
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provision is in place at the site. Access to images is permitted only to authorised employees, Police for
official investigations and other relevant authorised enforcement or regulatory agencies.
2.3 What type of transmission is used for the installation subject of this PIA (tick multiple options
if necessary)
Fibre optic
Wireless (please specify below)
Hard wired (apart from fibre optic,
Broadband
please specify)
Other (please specify)
The transmission is on a independantly secured wirelss network, which forms part of the wider
surveil ance scheme in Stockton on Tees.
2.4 What security features are there to protect transmission data e.g. encryption (please specify)
Safeguards, including technical, organisational and physical security measures are in place to prevent
unathorised access to, and maintain the integrity of, images and information obtained through
surveil ance. The Council holds ISO 27001 certification and has Cabinet Of ice approval - Public
Services Network (PSI).
2.5 Where wil the information be collected from?
Public places (please specify)
Car parks
Buildings/premises (external)
Buildings/premises (internal public areas) (please specify)
Al cameras which form part of this scheme are located in the public realm, at the side of an adopted
highway owned and maintained by the local authority.
Other (please specify)
2.6 From whom/what is the information collected?
General public in monitored areas (general observation)
Vehicles
Target individuals or activities (suspicious persons/incidents)
Visitors
Other (please specify)
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2.7 Why is the information being col ected? (Please refer to additional documentation where
available)
Crime prevention and detection
Traffic control purposes
Parking enforcement
Intelligence
Missing person(s)
Other (please specify)
The primary purpose of the scheme is to collect information via CCTV cameras for the detection and
prevention of crime in Ingleby Barwick.
2.8 How is the information used? (tick multiple options if necessary)
Used by CCTV operators to detect and respond to unlawful activities in real time
Used by CCTV operators to track and monitor suspicious persons/activity
Used to search for vulnerable persons
Used to search for wanted persons
Used to support post incident investigation by authorised agencies, including judicial system
Used to provide intelligence for authorised agencies
Other (please specify)
2.9 How long is footage stored? (please state retention period)
Al footage is stored for 31 ful days before being auto-deleted from the system. Appropriate manual
audit safeguards to ensure this occurs are also in place.
2.10 Retention Procedure
Footage automatically deleted after retention period
System operator required to initiate deletion
Under certain circumstances authorised persons may override the retention period e.g. retained for
prosecution agency (please explain your procedure)
2.11 With which external agencies/bodies is the information/footage shared?
Statutory prosecution agencies
Local Government agencies
Judicial system
Legal representatives
Data subjects
Other (please specify)
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2.12 How is the information disclosed to the authorised agencies
Only by onsite visiting
Copies of the footage released to those mentioned above (please specify below how released
e.g. sent by post, courier, etc)
Offsite from remote server
Other (please specify)
Footage can be released to those mentioned via pre-exiting evidence sharing procedures. This can be
done in physical form by visting the centre and signing for evidence or via an approved digital sharing
solution.
2.13 Is there a written policy specifying the fol owing? (tick multiple boxes if applicable)
Which agencies are granted access
How information is disclosed
How information is handled
Recipients of information become Data Controllers of the copy disclosed
Are these procedures made public?
Yes
No
Are there auditing mechanisms?
Yes
No
If so, please specify what is audited (e.g., disclosure, production, accessed, handled, received, stored
information)
The entire data collection, processing, storage, retention and dissemination is audited by the Data
Controller as required under the relveant stautory provision and assoicated guidance and best practice
regulations.Further independent auditing undertaken by certified inspectors such as National Security
Inspectorate and Surveil ance Commissioner.
2.14 Do operating staff receive appropriate training to include the fol owing?
Legislation issues
Monitoring, handling, disclosing, storage, deletion of information
Disciplinary procedures
Incident procedures
Limits on system uses
Other (please specify)
2.15 Do CCTV operators receive ongoing training?
Yes
No
2.16 Are there appropriate signs which inform the public when they are in an area covered by
surveil ance camera systems?
Yes
No
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3. Consultation requirements
Explain what practical steps you wil take to ensure that you identify and address privacy risks. Who
should be consulted internally and externally? How wil you carry out the consultation?
You can use consultation at any stage of the PIA process. It wil be necessary to concentrate any
consultation into ‘privacy issues’.
Note: there are guidelines on consultation for the public sector issued by the Cabinet Of ice and
elsewhere in this guidance.
3.1 Who have you consulted with? (tick multiple options if necessary)
Internal Consultations
Data Protection officer
Engineers, developers, designers, installers
Information Technology
Planning
Procurement
Data Processors
Corporate governance/Compliance
Research, analysts and statisticians
Senior management
Other (please specify)
External Consultations (tick multiple options if necessary)
General public
Local residents
Business
Education establishments
Elected Members (Council ors)
Other (please specify)
3.2 How did you undertake the consultation with the above (e.g. focus groups, on-line public
survey, public meetings, targeted mail survey, etc)? (please explain)
Consultation conducted as part of a project focus group involving key strategic partners and elected
Members.
3.3 Is feedback available to view?
Yes
No
3.4 What feedback did you have and have you acted on it? (please explain or attach results)
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4. Identify the privacy and related risks
The below table provides some examples of possible privacy risks related to the use of a CCTV system.
Operators can use this list as a starting point; however, not all of these risks may apply to all CCTV
systems or al PIAs.
Identify the key privacy risks and the associated compliance and corporate risks. Larger-scale PIAs
might record this information on a more formal risk register. Remember that the aim of a PIA is not to
completely eliminate the impact on a privacy risk. The options in dealing with the risks are to eliminate,
reduce or simply accept them.
Privacy issue
Risk to individuals
Compliance risk
Associated
organisation /
corporate risk
Collecting/ exceeding New surveil ance methods
Non-compliance with
Loss of reputation
purposes of CCTV
may be unjustified intrusion on Data Protection, Human
system
persons privacy especially
Rights legislation
Fines and sanctions
considering additional ANPR.
Retention of
Owner retaining personal
Non-compliance with
Loss of reputation
images/information
images/information longer
Data Protection, Human
for longer than
than necessary
Rights legislation
Fines and sanctions
necessary
Lack of policies and No public availability of CCTV Non-compliance with
Loss of reputation
procedures and
code of Practice which details Data Protection, Human
mechanisms
how personal data handled,
Rights legislation
Fines and sanctions
stored, disclosed etc.
Lack of signage
Public not made aware that
Non-compliance with
Loss of reputation
they are entering an area
Data Protection, Human
monitored by surveil ance
Rights legislation
Fines and sanctions
system.
Consider appropropriate
signage due to ANPR
additonal consideration.
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5. Identify privacy solutions
Describe the actions you could take to reduce the risks, and any future steps which would be necessary
(e.g. the production of new guidance or future security testing for systems).
Note: please mark any ‘privacy by design’ solutions with an asterisk *
Risk
Solution(s)
Result: is the
Evaluation: is the final impact on
risk eliminated, individuals after implementing
reduced, or
each solution a justified, compliant
accepted?
and proportionate response to the
aims of the project?
Collection of
Restrict collection of
Reduced
If the images were reduced to the
images/information images/information to identified
identified purposes by introducing
exceeds purposes purposes and locations.
‘Privacy zones’. The collection of
Implement appropriate
images/ information would be
technological security measures
justified, compliant and
and document these.
proportionate
Retention of
Introduce retention periods to
Reduced
As stated retention periods
images/information only keep information for as
introduced and specified are
long as necessary. These are
justified, compliant and
specified in the publicly
proportionate to data protection
available CCTV Codes of
legislation.
Practice.
Additonal manual check of
Introduce automatic system
automated system to safeguard
safeguards and ensure
system failure.
auditable checking of sytem.
Lack of policies
Produce polices for handling,
Eliminated
Relevant policies now available as
and procedures
storage, disclosure of
stated, online.
and mechanisms images/information and make
them publicly available in the
This is now justified, compliant and
CCTV Codes of Practice.
proportionate as audited by the
National Security Inspectorate.
Lack of signage
Gap analysis of area covered by Reduced
Gap analysis indicated not enough
CCTV system to ascertain if
prominent signs. Now installed an
there is prominently placed
additional sign to the column of the
signage at the entrance to the
camera as part of the scheme.
area monitored and also within
This is now justified, compliant and
that area. Al signs to be audited
proportionate.
regularly.
Ensure appropriate signage in
place in the immediate area
around the cameras installed as
part of the scheme.
Consider additonal signage in
the approaching areas as a
supplement.
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Risk
Solution(s)
Result: is the
Evaluation: is the final impact on
risk eliminated, individuals after implementing
reduced, or
each solution a justified, compliant
accepted?
and proportionate response to the
aims of the project?
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6. Sign off and record the PIA outcomes
This section is for the decision maker in the organisation to sign off each risk. Who has approved the
privacy risks involved in the project; what solutions need to be implemented; who and at what level?
The example below shows the information required. You wil need to list each identified risk, solution and
approved sign off.
Risk
Approved solution
Approved by
Collection of images/
Restrict collection of
Jamie Stephenson - Operations
information exceeds purposes images/information to
Manager
identified purposes and
locations.
Implement appropriate
technological security
measures and document.
Retention of
Introduce retention periods to Jamie Stephenson - Operations
images/information
only keep information for as
Manager
long as necessary. These are
specified in the publicly
available CCTV Codes of
Practice.
Lack of policies and
Produce polices for handling, Jamie Stephenson - Operations
procedures and mechanisms storage, disclosure of
Manager
images/information and make
them publicly available in the
CCTV Codes of Practice.
Lack of signage
Gap analysis of area covered Jamie Stephenson - Operations
by CCTV system to ascertain Manager
if there is prominently placed
signage at the entrance to the
area monitored and also within
that area. Al signs to be
mapped and audited regularly.
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Risk
Approved solution
Approved by
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Document Outline
