Dear Home Office,

The latest Zengrab CCTV bus lane monitoring devices have a module for automatic contravention detection. When configured they display the word Contravention on CCTV images that will later be used as evidence in civil proceedings. As the Contravention is not proven at the time of data capture this may prejudice subsequent enforcement action and legal proceedings.

Can you confirm whether the use of this equipment in this way is in contravention of legislation governing the use of CCTV surveillance systems, legislation governing the enforcement of bus lanes, legislation governing the use of evidence and the Human Rights Act.

Can you also confirm that the use of the term Contravention in evidence captured this way is unlawful as it breaches the principle of presumed innocence especially in circumstances where there may be very good grounds for proving that the alleged contravention did not take place as is often the case.

If this specific use of CCTV is unlawful, can you confirm that images produced with the word Contravention automatically overlayed on them are inadmissable as evidence for raising penalty charge notices and in Tribunals or High Court proceedings. Unless the CCTV system producing them is infallible (which is not the case) the term used should be Alleged or Possible Contravention.

Yours faithfully,

Charles Dawson