Automatic Number Plate Recognition System (ANPR) governance arrangements, board papers

william perrin made this Freedom of Information request to National Police Chiefs' Council
This authority is not subject to FOI law, so is not legally obliged to respond (details).

The request was partially successful.

Dear National Police Chiefs Council,

ANPR is a powerful crime fighting tool The system gathers very large amounts of data daily about people's movements and stores it for a number of years. In the five year strategy, “Policing the Roads in Partnership 2015 – 2020” National Lead for Policing the Roads
Chief Constable Suzette Davenport set out some basic principles, one of which was :

'Accountability – we are answerable for our decisions, actions and omissions'.

Issues arising from a system on the scale of ANPR such as privacy can be mitigated by good system design and effective governance. I should be grateful for information you hold in your records about the governance of the ANPR system, particularly at a national level such as (but not exclusively):

structure of governance - committees, their membership
papers and minutes produced or consumed by or within the governance structure - such as board papers, minutes of meetings, records of decisions taken
correspondence with the Information Commissioner's office about the system

I am interested in the period 2013-2015 but would welcome relevant information you may hold prior to that time.

ANPR is almost unique globally in its scale and, as it holds billions of records of people's movements there is a very strong public interest in publishing the information I request.

I would invite you also to add such information to your publication scheme on an ongoing basis. If you do publish this already then please point me to it - I can't find a reserve of documents about ANPRs operation and governance on your websites.

I prefer to receive information electronically through this service. If you can answer only part of this request then please do so rather than rejecting the whole thing. Should you require any clarification in order to answer this request then please contact me through this service.

Yours faithfully,

william perrin

National Police Chiefs' Council

Dear Mr Perrin

Thank you for your email and request for information in relation to ANPR.

Unfortunately, I am unclear as to what recorded information that you seek from the NPCC.

I have interpreted your request to be asking for the following information held by the NPCC National Policing Lead / ANPR Working Group:

1. For the financial years 2013 - 2015 please provide any record which details the structure and governance of the ANPR system.

2. For the financial years 2013 - 2015 please provide any minutes of the ANPR Working Group.

3. For the financial years 2013 - 2015 please provide all recorded communication with the Information Commissioner's Office (ICO).

I would be grateful if you could respond to this email at your earliest opportunity, or at the latest, within 20 working days. I am unable to formally acknowledge your request until clarification is received.

Kind regards

Sherry

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Dear National Police Chiefs Council,

Thank you for this - i had thought i had sent a clarification upon receipt of your request but the web service seems to have lost it.

Anyway - thank you for that the information as you have set it out will suffice for this request with one clarification, i seek only recorded communication with the ICO office in respect of ANPR, not across the whole sweep of your organisations activities.

The opacity of the governance arrangements for ANPR makes it hard to get this request right first time.

Yours faithfully,

william perrin

National Police Chiefs' Council

2 Attachments

Good afternoon Mr Perrin
 
Please find attached NPCC acknowledgement to your Freedom of Information 
request.
 
With kind regards
 
Sherry
 

Sherry Traquair

Freedom of Information Officer and Decision Maker

[1]NPCC-blue-RGB

National Police Chiefs' Council, 1st Floor,

10 Victoria Street, London, SW1H 0NN

T  | 02380 478922

M | 077 685 53447

E  | [National Police Chiefs Council request email]

W| [2]www.npcc.police.uk 

 
 

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National Police Chiefs' Council

2 Attachments

Good afternoon Mr Perrin
 
Please find attached notification of delay in relation to your Freedom of
Information request. 
 
May I take this opportunity to thank you for your continued patience.
 
Kindest regards.
 
Sherry

Sherry Traquair

Freedom of Information Officer and Decision Maker

National Police Chiefs' Council, 1st Floor,

10 Victoria Street, London, SW1H 0NN

T  | 02380 478922

M | 077 685 53447

E  | [National Police Chiefs Council request email]

W| [1]www.npcc.police.uk 

For out of hours press enquiries please call 07803 903 686

[2]twitter-02

 

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3. mailto:[email address]

Dear National Police Chiefs Council,

Thank you for this Sherry

In conducting a public interest test I should be interested to know how you weigh up the positive aspects of releasing the information and who you talk to to weigh up the positive side of a public interest balance. I have a correspondence with the Surveillance Camera Commissioner Tony Porter and he said that he would welcome increased transparency about ANPR governance.

In the public interest i should ask you to note that:

The UK ANPR system is one of the world's largest systems for recording the movements of private individuals.

The ANPR system contains over 1 billion records

At this scale, how this data governed and matters arising from that governance are of very significant public interest indeed.

I should remind you that I have sought three types of information and asked that if you cannot meet all of them then please do what you can rather than reject all of it.

I find it hard to conceive that disclosing information about the structure of governance, what happens within that governance and issues that needed to be raised with the ICO can actually harm the public interest at a scale that would be less than the good caused given the scale and nature of data involved.

Yours faithfully,

william perrin

National Police Chiefs' Council

Mr Perrin

Thank you for your email and may I provide assurances that I am well aware of my obligations in relation to public interest considerations.

Sherry

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National Police Chiefs' Council

15 Attachments

Mr Perrin

Please find attached NPCC response to your Freedom of Information request.

Many thanks.

Sherry

Sherry Traquair

Freedom of Information Officer and Decision Maker

National Police Chiefs' Council, 1st Floor,

10 Victoria Street, London, SW1H 0NN

T  | 02380 478922

M | 077 685 53447

E  | [National Police Chiefs Council request email]

W| [1]www.npcc.police.uk 

For out of hours press enquiries please call 07803 903 686

 

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References

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1. http://www.npcc.police.uk/
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Richard Taylor left an annotation ()

An article which appears to be based on this release has appeared in the Sunday Times on the 13th of December 2015 with the headline : "Police may log your car trips for decade".

There is a quote from the requstor.

http://www.thesundaytimes.co.uk/sto/news...

Much of the article is behind a paywall.

Richard Taylor left an annotation ()

The letter from the Information Commissioner released in response to this request includes the following:

"As things stand at present, it is virtually impossible for a motorist using the road network to determine who is the data controller operating the ANPR cameras and who might be holding the data obtained. This not only engages concerns about fair processing it frustrates other important data protection rights such as being able to make a subject access request. This lack of transparency needs rectifying as data is being collected by an ever expanding network of cameras, retained on a national system for two years and the vast majority of the retained records are about the use of vehicles which cause no concern to the police either immediately or over time. We have estimated that approximately 10 billion records are acquired annually - if you move into a retention period of between seven and ten years this is a significant amount of data being retained recording the movements of individuals as they go about their lawful day to day activities. There is very little transparency for the motorists who use the road network and have their vehicle movement details harvested in this way."

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