CCTV warning signs

Transport for London did not have the information requested.

Dear Transport for London,

1. Do you keep any sort of record of the locations of your CCTV warning signs?

2. If not, how do you ensure compliance with the requirements of the Data Protection Act? If yes, then please specify what sort of records you keep.

3. Where are the nearest 6 CCTV warning signs to the junction of Parkfield Road and Lewisham Way?

Yours faithfully,

D Cox

FOI, Transport for London

Dear D Cox
 
TfL Ref: FOI-0484-1213
 
Thank you for your email received by Transport for London (TfL) on 22 June
2012 asking for information about CCTV warning signs.
 
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 23 July 2012.
 
In the meantime, if you would like to discuss this matter further, please
do not hesitate to contact me.
 
Yours sincerely
 
Eva Rozmahelova
FOI Case Officer
 
FOI Case Management Team
Corporate Governance Directorate
General Counsel
Transport for London
 
 

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bernie left an annotation ()

Did you get the information you requested?

FOI, Transport for London

1 Attachment

Dear D Cox

 

TfL Ref: FOI-0484-1213

 

Thank you for your email received by Transport for London (TfL) on 22 June
2012 asking for information about CCTV warning signs.

 

Your request has been considered in accordance with the requirements of
the Freedom of Information Act and TfL’s information access policy.  I can
confirm TfL holds some of the information you require. You asked for:

 

1.    Do you keep any sort of record of the locations of your CCTV warning
signs?

 

TfL does not keep records of CCTV warning signs.

 

However the CCTV Code of Practice (Revised edition 2008) states “You must
let people know when they are in an area where CCTV surveillance is
carried out” and “Clear and prominent signs are particularly important in
locations where people might not expect to be under surveillance. As a
general rule, signs should be more prominent and frequent where it would
otherwise be less obvious to people that they are on CCTV.” 

 

The Code of Practice does not set out that warning signs must be sited
adjacent to each and every location where CCTV enforcement takes place. 
Although we have a number of these signs throughout the Transport for
London Road Network (TLRN), we do not keep records of their locations. 

    

2.    If not, how do you ensure compliance with the requirements of the
Data Protection Act? If yes, then please specify what sort of records you
keep.

 

Traffic congestion in London has been subject to CCTV enforcement for a
number of years, and this method of enforcement within London is generally
well known and understood by the public.  TfL is satisfied that the
general presence of warning signs in the areas leading up to the point
where enforcement takes place is sufficient to ensure compliance with the
processing requirements of the Data Protection Act (DPA) 1998.  Under the
terms of the Act, the statutory requirement for data controllers (such as
TfL) is to notify the ICO where personal data is being processed and the
purpose for which it is processed.  The ICO maintains a register of all
notifications; TfL’s notification is available to view using the following
link: [1]http://www.ico.gov.uk/ESDWebPages/Search...

 

Further information on the requirement to notify is available
here:[2]http://www.ico.gov.uk/for_organisations/....

 

3.    Where are the nearest 6 CCTV warning signs to the junction of
Parkfield Road and Lewisham Way?

 

Please refer to our answer in question 1 above.

 

If this is not the information you are looking for, or if you are unable
to access it for some 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

 

Eva Rozmahelova

FOI Case Officer

 

FOI Case Management Team

Corporate Governance Directorate

General Counsel

Transport for London

 

 

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Dear Eva,

thank you for your reply and thank you for confirming that you keep no record at all of the locations of CCTV warning signs. However you do say you have a "number" of signs throughout the TLRN: approximately how many is a "number"?

Presumably you keep track of your expenditure on signs so please state how much you spent on CCTV warning signage in the last 12 months as a way of answering my original question more helpfully.

You say there is a "general presence" in the area leading up to where enforcement takes place but I cannot see any leading up to this particular junction: please could you point me to even one that is in the area? I have looked.....

You quote part of the Code of Practice relating to places where people might not expect to be under surveillance. A more relevant part of the Code states:

"Signs should:

be clearly visible and readable;
contain details of the organisation operating the system, the purpose for using CCTV and who to contact about the scheme (where these things are not obvious to those being monitored); and
be an appropriate size depending on context, for example, whether they are viewed by pedestrians or car drivers."

How can you be sure that you have visible and readable signs if you have no record at all of how many you have and where they are situated? The ICO nowhere mentions that operators can rely on having had CCTV cameras for a "number of years" as reducing the need for signage: I am not clear if that is what you are trying to say? Please confirm.

Thank you for your help and time,

Yours sincerely,

D Cox

FOI, Transport for London

Dear D Cox

TfL Ref: FOI-0565-1213

Thank you for your email received by Transport for London (TfL) on 6 July 2012 asking for further information about CCTV warning signs.

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 7 August 2012.

In the meantime, if you would like to discuss this matter further, please do not hesitate to contact me.

Yours sincerely

Eva Rozmahelova
FOI Case Officer

FOI Case Management Team
Corporate Governance Directorate
General Counsel
Transport for London

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FOI, Transport for London

3 Attachments

Dear D Cox

 

TfL Ref: FOI-0565-1213

 

Thank you for your email received by Transport for London (TfL) on 6 July
2012 asking for further information about CCTV warning signs.

 

Your request has been considered in accordance with the requirements of
the Freedom of Information (FOI) Act and TfL’s information access policy. 

 

Unfortunately TfL does not hold the information you have requested. You
asked for:

 

However you do say you have a "number" of signs throughout the TLRN:
approximately how many is a "number"?

 

You say there is a "general presence" in the area leading up to where
enforcement takes place but I cannot see any leading up to this particular
junction: please could you point me to even one that is in the area?

 

As advised in our earlier response (attached), TfL does not hold this
information.

 

Presumably you keep track of your expenditure on signs so please state how
much you spent on CCTV warning signage in the last 12 months as a way of
answering my original question more helpfully.

 

TfL does not hold the information requested as we do not hold expenditure
details broken down by sign type.

 

How can you be sure that you have visible and readable signs if you have
no record at all of how many you have and where they are situated? The ICO
nowhere mentions that operators can rely on having had CCTV cameras for a
"number of years" as reducing the need for signage: I am not clear if that
is what you are trying to say? Please confirm.

 

The ICO Code of Practice has the status of guidance only.  Whilst
authorities such as TfL must have regard to their guidance around warning
signs, statutory requirements are set out only in the Traffic Signs
Regulations and General Directions (TSRGD) 2002.  The TSRGD does not set
out where camera warning signs must be displayed; rather the requirement
is that where they are displayed, they must be of the size and type
prescribed (to Diagram 878 and Diagram 879).  Our earlier response did not
state that we consider the need for signage has reduced but that we are
satisfied their general presence fulfils the data processing requirements
of the Data Protection Act. 

 

TfL is not under a statutory duty to erect camera enforcement warning
signs.

 

Please accept my apologies that we are unable to assist you further on
this occasion. 

 

Please see the attached information sheet for details of your right to
appeal.

 

Yours sincerely

 

Eva Rozmahelova

FOI Case Officer

 

FOI Case Management Team

Corporate Governance Directorate

General Counsel

Transport for London

 

 

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Malcom Briggs left an annotation ()

Transport for London have signed up to the Code of
Practice for Operation of CCTV Enforcement Cameras published by 'The London Councils'.
The following statement is in the London Councils code of practice. “CCTV in public places MUST be operated with regard to the advice and guidelines issued by…. Office of Data Protection Registrar”(ICO).

Below is part of a decision of the ICO.

“It is worth clarifying that the Information Commissioner’s CCTV Code of Practice is intended to help CCTV operators comply with their legal obligations and is not just aimed at the virtuous who
want to adopt best practice. It sets out the Information Commissioner’s recommendations on how the legal requirements of the Data Protection Act can be met and these are based on the legally enforceable data protection principles.”