CCTV, Surveillance Camera and all other Camera and camera systems codes of practice
Dear Wirral Metropolitan Borough Council,
Online I can find individually a few different wirral council codes of practice from different times relating to cctv but there is no way to tell if such codes are current and complete.
Relating to any cctv, surveillance camera and all other camera and camera systems of any kind please provide a full and complete list of all current codes of practice that wholly or in part affect them, and provide copies.
Yours faithfully,
John Jones
Dear Mr Jones
Please find attached the Council’s current Code Of Practice in relation to
CCTV.
Yours sincerely
Lynette Paterson
Principal Information Management Officer
Finance – Digital and Improvement
Wirral Council
PO Box 290
Brighton Street
Wallasey
CH27 9FQ
Email: [1][Wirral Borough Council request email]
Visit our website: [2]www.wirral.gov.uk
This email and any files transmitted with it are confidential and intended
solely for the use of the individual or entity to whom they are addressed.
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References
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1. mailto:[Wirral Borough Council request email]
2. http://www.wirral.gov.uk/
Dear InfoMgr, FinDMT,
Please confirm that is the most recent policy since it is dated 1st march 2014.
Please also provide all the other policies it refers to in 1.3, and confirm the full list of all current policies as I originally requested and if there are any more than listed in 1.3 please provide them as well.
Yours sincerely,
John Jones
Dear InfoMgr, FinDMT,
There is also another policy referred to in 1.2, please provide that also.
Yours sincerely,
John Jones
Dear Wirral Metropolitan Borough Council,
Please pass this on to the person who conducts Freedom of Information reviews.
I am writing to request an internal review of Wirral Metropolitan Borough Council's handling of my FOI request 'CCTV, Surveillance Camera and all other Camera and camera systems codes of practice'.
REASONS -
It is now 34 working days since my original request of 18/01/2024, and 21 working days since your unclear and anyway incomplete response of 06/02/2024 which that same day I sent two messages about and since which I have received no reply.
A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/c...
Yours faithfully,
John Jones
Dear Mr Jones
We write in response to your request for an internal review and further
question submitted following our response to you 6 February 2024.
That original enquiry 18 January 2024 asked:
‘Online I can find individually a few different wirral council codes of
practice from different times relating to cctv but there is no way to tell
if such codes are current and complete.
Relating to any cctv, surveillance camera and all other camera and camera
systems of any kind please provide a full and complete list of all current
codes of practice that wholly or in part affect them, and provide copies.’
The Council’s current Code Of Practice in relation to CCTV was provided
to you in response on 6 February 2024
You have further asked 6 February 2024
‘Please confirm that is the most recent policy since it is dated 1st march
2014. Please also provide all the other policies it refers to in 1.3, and
confirm the full list of all current policies as I originally requested
and if there are any more than listed in 1.3 please provide them as well.
There is also another policy referred to in 1.2, please provide that also’
Wirral Council can confirm The Code Of Practice 2014 version provided in
your response is the most current version.
The Council do not have any of the additional documents mentioned in the
2014 Code Of Practice and you have been provided with everything held.
However to assist and advise you with your questions we can further
confirm this version is under review by the Council.
This concludes the internal review. Your next step would be to complain
to the Information Commissioner‘s Office if you remain dissatisfied.
The information Commissioner details can be found at this link
[1]https://ico.org.uk/global/contact-us/
Yours sincerely
Tracy O'Hare
Information Management Officer
Wirral Council
PO Box 290
Brighton Street
Wallasey
CH27 9FQ
Email:[2][Wirral Borough Council request email]
Visit our website: [3]www.wirral.gov.uk
This information supplied to you is copyrighted and continues to be
protected by the Copyright, Designs and Patents Act 1988. You are free
to use it for your own purposes, including any non commercial research you
are doing and for the purposes of news reporting. Any other reuse, for
example commercial publication, would require our specific permission, may
involve licensing and the application of a charge
Dear InfoMgr, FinDMT,
The next stage is not the ICO as your internal review is simply incomplete.
The 2014 code of practice you provided a copy of states it is concerned with general principles and that there are more specific codes published by the council for particular circumstances including:-
1 If the cameras are used to carry out surveillance of persons in a manner calculated to ensure that they are unaware it is taking place then the operators of the cameras will be subject to the policy and procedure published by the Council on covert surveillance under the Regulation of Investigatory Powers Act 2000 (RIPA).
2 the monitoring and enforcement of traffic and parking regulations
3 the system jointly used by Merseyside Police to monitor behaviour by the public in public places
4 systems installed in vehicles to monitor and record anti-social behaviour
Having confirmed the 2014 code you provided is the most recent, you say the council do not have any of the additional documents mentioned within it.
Have all copies of these documents held by the council been destroyed?
Whether these or later versions, does the council no longer have any specific codes for the particular circumstances 1 to 4 listed above in this message?
If not when did the council decide to abolish each of these specific codes?
Please provide all information held regarding the decisions to abolish them.
Yours sincerely,
John Jones
Dear InfoMgr, FinDMT,
It is now 21 working days since my 07/03/2024 message regarding your incomplete internal review and you have not responded.
Yours sincerely,
John Jones
Dear Mr Jones
We write in response to your request for an internal review of the
Council’s handling of your FOI request and apologise for the delay in
replying. In your email of 7 March 2024, you stated that the response was
incomplete and posed the following 4 questions :
The 2014 code of practice you provided a copy of states it is concerned
with general principles and that there are more specific codes published
by the council for particular circumstances including:-
1 If the cameras are used to carry out surveillance of persons in a manner
calculated to ensure that they are unaware it is taking place then the
operators of the cameras will be subject to the policy and procedure
published by the Council on covert surveillance under the Regulation of
Investigatory Powers Act 2000 (RIPA).
2 the monitoring and enforcement of traffic and parking regulations
3 the system jointly used by Merseyside Police to monitor behaviour by the
public in public places
4 systems installed in vehicles to monitor and record anti-social
behaviour
We have now reviewed the original response and can advise as follows in
respect of your 4 questions set out above.
1. The Council’s Policy on the use of directed surveillance
under the Regulation of Investigatory Powers Act 2000 is attached.
2. The Council’s Code of Practice for the use of CCTV for
traffic enforcement is attached.
3. The joint operation of the public realm CCTV cameras by
Merseyside Police is dealt with in the new draft Code of Practice, which
is not yet published.
4. The Council does not currently use covert cameras secured in
vehicles to monitor and record anti-social behaviour.
As we have now addressed the 4 points that formed your internal review
request, we consider this to be closed. If you are dissatisfied, you
should refer to the Information Commissioner at [1]www.ico.org.uk
Yours sincerely
Lynette Paterson
Principal Information Management Officer
Finance – Digital and Improvement
Wirral Council
PO Box 290
Brighton Street
Wallasey
CH27 9FQ
Email: [2][Wirral Borough Council request email]
Visit our website: [3]www.wirral.gov.uk
This email and any files transmitted with it are confidential and intended
solely for the use of the individual or entity to whom they are addressed.
If you have received this email in error please notify the system manager.
References
Visible links
1. http://www.ico.org.uk/
2. mailto:[Wirral Borough Council request email]
3. http://www.wirral.gov.uk/
Dear InfoMgr, FinDMT,
The next step is not the ICO as your internal review is clearly defective and incomplete.
On 07/03/2024 you said ‘The Council do not have any of the additional documents mentioned in the 2014 Code Of Practice and you have been provided with everything held.’ On 22/04/2024 in your delayed response to my request for an internal review you provided a copy of some of those additional documents. But you offered no explanation as to why on 07/03/2024 you incorrectly told me the council did not hold them. Please explain.
For the joint operation of the public realm CCTV cameras by Merseyside Police you say it is being dealt with in a new draft code of practice which is not yet published. As I asked previously please provide a copy of the version of that on public realm referred to in the 2014 Code of Practice or confirm all copies held by the council have been destroyed. Also confirm and provide information relating to the decision to abolish that code. Also detail and copies of any subsequent versions intervening between that version and the current draft and decisions to abolish them. Also please clarify whether the joint operation of the public realm CCTV cameras by Merseyside police is currently proceeding without any council code of practice or that it is proceeding with the draft version that has yet to be published. If with a draft please provide or confirm the valid FOIA reasons for not supplying me with it.
Regarding the covert camera code the council not currently using those cameras does not mean the code has been abolished and all copies destroyed. Please clarify.
Please also as previously requested confirm the current full list of cctv codes of practice held by the council.
Yours sincerely,
John Jones
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