Kingdom Services Group "Non Encrypted Body Worn Cameras"

The request was successful.

Dear Tunbridge Wells Borough Council,

I recently observed enforcement officers working for Kingdom Services Group Limited using PR5 Body Worn Cameras (not encrypted). To that end, could you answer the following questions.

1. Could you confirm that the Enforcement Officers employed by Kingdom Services Group Limited, who are working on behalf of your council as authorised officers are no longer using Pinnacle PR5 Body Worn Cameras, which are not encrypted to protect the Personal Identifiable Information obtained from members of the public during the issuance of a Fixed Penalty Notice?

2. Could you confirm the number of Fixed Penalty Notices issued by Kingdom Services Group Limited using a PR5 Body Worn Cameras since 25th May 2018?

3. could you break the answer from question 2 down into paid, cancelled, written off and unpaid FPNs?

4. Although, all devices which are being used to record personal identifiable information should be encrypted as per GDPR 2016. If Kingdom Services Group are refusing to upgrade their body-worn cameras to the encrypted model, could you send me a copy of the Data Protection Impact Assessment (DPIA) which clearly shows the risks of having an un-encrypted body worn camera and the measures in place to protect the personal identifiable information of the general public who come into contact with the council's authorised officers working on behalf of Kingdom Services Group Limited?

5. Did you know that the files on a PR5 camera can be accessed from any computer?

6. Did you know that Kingdom officers take these cameras home at the end of each shift, therefore data can be removed and manipulated?

7. Did you know Kingdom have had three separate data breaches in the past 3 months with regards to the loss of PR5 cameras?

8. Did you know that you (the council) are joint controllers under GDPR 2016 and the council would also incur a large fine if a breach is proven?

9. This is the link to a data breach involving Kingdom at Anglesey Council and the council was deemed to be the data controller by ICO even though Kingdom lost the notebook.

https://www.dailypost.co.uk/news/north-w...

If my questions above are not answered fully or the fact Kingdom's officers have issued Fixed Penalty Notices since 25th May 2018 using PR5 cameras is denied. I will submit all of my evidence to the press, Information Commissioners Office and Ombudsman.

Yours faithfully,

M Mounty

info (TWBC), Tunbridge Wells Borough Council

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FOI (TWBC), Tunbridge Wells Borough Council

3 Attachments

Dear M Mounty

Acknowledgement

Our Ref: FOI F07231

Thank you for your recent email which we are handling in accordance with
the Freedom of Information Act 2000. I acknowledge receipt and confirm
that we will respond within 20 working days from the date of receipt; by
no later than the 25^th September 2018

In the meantime, if you have any further queries regarding our Freedom of
Information procedures please contact the team on 01892 554077 or via
e-mail to [1][email address].

Yours sincerely

 

 

 

Jessica Cox LLB

Corporate Governance Assistant

 

T: 01892 554077 ext: 4077

E: [2][email address]

Town Hall, Royal Tunbridge Wells, Kent, TN1 1RS

 

[3]www.tunbridgewells.gov.uk   

 

 

 

This e-mail is confidential and intended solely for the use of the individual to whom it is addressed. Any views or opinions presented are solely those of the author and do not necessarily represent those of Tunbridge Wells Borough Council. If you are not the intended recipient, be advised that you have received this e-mail in error and that any use, dissemination, forwarding, printing or copying of this e-mail is strictly prohibited.

If you have received this e-mail in error please notify Tunbridge Wells Borough Council on telephone +44 (0)1892 526121 or e-mail to [Tunbridge Wells Borough Council request email].

References

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1. mailto:[email address]
2. mailto:[email address]
3. http://www.tunbridgewells.gov.uk/

FOI (TWBC), Tunbridge Wells Borough Council

3 Attachments

Dear M Mounty

Re: FOI F07231

Thank you for your Freedom of Information request and please accept my
sincere apologies for the delay.

Please find below the response to your recent request. The information has
been provided by our Waste and Street Scene Team.

Your request:

 1. Could you confirm that the Enforcement Officers employed by Kingdom
Services Group Limited, who are working on behalf of your council as
authorised officers are no longer using Pinnacle PR5 Body Worn
Cameras, which are not encrypted to protect the Personal Identifiable
Information obtained from members of the public during the issuance of
a Fixed Penalty Notice?

Pinnacle PR5 body worn cameras used.

 

 2. Could you confirm the number of Fixed Penalty Notices issued by
Kingdom Services Group Limited using a PR5 Body Worn Cameras since
25th May 2018?

395

 

 3. Could you break the answer from question 2 down into paid, cancelled,
written off and unpaid FPNs?

As of 2^nd October 2018

262 Paid

81 Unpaid

15 Cancelled

39 Written off

 

 4. Although, all devices which are being used to record personal
identifiable information should be encrypted as per GDPR 2016. If
Kingdom Services Group are refusing to upgrade their body-worn cameras
to the encrypted model, could you send me a copy of the Data
Protection Impact Assessment (DPIA) which clearly shows the risks of
having an un-encrypted body worn camera and the measures in place to
protect the personal identifiable information of the general public
who come into contact with the council's authorised officers working
on behalf of Kingdom Services Group Limited?

I confirm that the Council does not hold the data requested.

 

 5. Did you know that the files on a PR5 camera can be accessed from any
computer?
 6. Did you know that Kingdom officers take these cameras home at the end
of each shift, therefore data can be removed and manipulated?
 7. Did you know Kingdom have had three separate data breaches in the past
3 months with regards to the loss of PR5 cameras?
 8. Did you know that you (the council) are joint controllers under GDPR
2016 and the council would also incur a large fine if a breach is
proven?

 

In response to questions 5,6,7 and 8; the purpose of the Freedom of
Information Act 2000 is to allow individuals access to all ‘recorded’
information’ and does not cover requests for interpretations or
information that is not already in recorded form.

 

The Council considers that these questions are not requests for recorded
information and fall outside the scope of the Act. However, we have
referred your concerns to our Data Protection Team.

 

 

I hope this information is helpful and if there is anything further I can
help with please contact me on 01892 554077 or via email to
[1][email address

If you are dissatisfied with the information provided or the way in which
we have dealt with your request, you can request a review.   Please write
to Patricia Narebor, Head of Legal Partnership and Monitoring Officer at
the Town Hall, Royal Tunbridge Wells, Kent, TN1 1RS or via e-mail to
[2][email address]  requesting a review of the
decision.

We will aim to deal with your request within 20 working days. If you
remain dissatisfied following our review, you can then appeal to the
Information Commissioner.

Yours sincerely

 

 

 

Jessica Cox LLB

Corporate Governance Assistant

 

T: 01892 554077 ext: 4077

E: [3][email address]

Town Hall, Royal Tunbridge Wells, Kent, TN1 1RS

 

[4]www.tunbridgewells.gov.uk   

 

 

 

This e-mail is confidential and intended solely for the use of the individual to whom it is addressed. Any views or opinions presented are solely those of the author and do not necessarily represent those of Tunbridge Wells Borough Council. If you are not the intended recipient, be advised that you have received this e-mail in error and that any use, dissemination, forwarding, printing or copying of this e-mail is strictly prohibited.

If you have received this e-mail in error please notify Tunbridge Wells Borough Council on telephone +44 (0)1892 526121 or e-mail to [Tunbridge Wells Borough Council request email].

References

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1. mailto:[email address]
2. mailto:[email address]
3. mailto:[email address]
4. http://www.tunbridgewells.gov.uk/