Please can you provide a copy of the Data Protection Impact Assessment undertaken before introduction of ANPR cameras to manage parking at Colchester General Hospital?

The request was successful.

Dear East Suffolk and North Essex NHS Foundation Trust,

Parking control by means of Automatic Number Plate Recognition (ANPR) is being introduced at Colchester General Hospital. This will mean that for infringement of parking regulations a Parking Charge Notice will be sent to the Registered Keeper (RK) of the vehicle. In a hospital setting this has serious implications for patient confidentiality. A patient who is the dhe driver of the vehicle may inadvertently incur a PCN but not wish the RK to know that they attended the hospital e.g. domestic abuse or many other reasons

This introduction of ANPR cameras means that patient confidentiality in attending the hospital is now compromised. Please can you provide a copy of the Data Protection Impact Assessment that has been undertaken prior to the introduction of this scheme?

Yours faithfully,

Nigel Barker

FOI Requests CGH, East Suffolk and North Essex NHS Foundation Trust

Dear Nigel,

 

Reference number: 5122

 

I am writing to acknowledge receipt of your request under the Freedom of
Information Act 2000 to East Suffolk and North Essex Foundation Trust
(ESNEFT), received on 14/09/2018. Your enquiry has been logged and
forwarded to the appropriate department for action. Please note that the
Act allows 20 full working days to provide a response although we will
endeavour to do so before then. The deadline is calculated to be
12/10/2018.

 

If you have any queries regarding your request, please do not hesitate to
contact me on this email address.

 

Kind regards,

Amy

 

Amy Witham

Information Governance Administrative Assistant

East Suffolk and North Essex NHS Foundation Trust

Based at: Ipswich Hospital

Email: [1][email address]

Telephone: 01473 702878 ext 1878

 

show quoted sections

FOI Requests CGH, East Suffolk and North Essex NHS Foundation Trust

1 Attachment

Thank you for your recent enquiry regarding information held by the East
Suffolk and North Essex NHS Foundation Trust:

 

Parking control by means of Automatic Number Plate Recognition (ANPR) is
being introduced at Colchester General Hospital. This will mean that for
infringement of parking regulations a Parking Charge Notice will be sent
to the Registered Keeper (RK) of the vehicle. In a hospital setting this
has serious implications for patient confidentiality. A patient who is the
driver of the vehicle may inadvertently incur a PCN but not wish the RK to
know that they attended the hospital e.g. domestic abuse or many other
reasons

 

This introduction of ANPR cameras means that patient confidentiality in
attending the hospital is now compromised. Please can you provide a copy
of the Data Protection Impact Assessment that has been undertaken prior to
the introduction of this scheme?

 

Your enquiry has been dealt with in accordance with the Trust’s Freedom of
Information Act 2000 Policy and Procedures. We are pleased to enclose the
information you requested:

 

Please find attached the Data Protection Impact Assessment for the ANPR
parking scheme.

 

If you have any queries about the enclosed information please contact us,

 

The Public Sector Information Regulations provide a framework for public
sector organisations to licence the re-use of their information.  Please
request a re-use licence in order to re-use the information. Without the
necessary permission, you can breach our copyright.

 

Brief extracts of any material may be reproduced without our permission,
under the “fair dealing” provisions of the Copyright, Designs and Patents
Act 1988 for the purposes of research for non-commercial purposes; private
study; criticism; review and news reporting. All are subject to an
acknowledgement of ourselves as the copyright owner.  For guidance notes
on a range of copyright issues, see the Office of Public Sector
Information web site.

 

If you are unhappy with the service you have received in relation to your
request you should write to us. Please also contact us if you require a
copy of our Freedom of Information Act 2000 Complaints Procedure.  Any
complaints you wish to make in relation to Environmental Information
Regulations (EIR) requests, must be sent to us within 40 working days of
receipt of this letter.

 

If you remain dissatisfied with the handling of your request or complaint,
you have a right to appeal to the Information Commissioner at:

 

The Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Telephone: 08456 30 60 60 or 01625 54 57 45

Website: [1]www.ico.org.uk

 

There is no charge for making an appeal.

 

We hope that we have been able to answer your query to your satisfaction
and that you find the information provided useful.

 

Regards,

 

Amy Witham

Information Governance Administrative Assistant

East Suffolk and North Essex NHS Foundation Trust

Based at: Ipswich Hospital

Email: [2][email address]

Telephone: 01473 702878 ext 1878

 

References

Visible links
1. http://www.ico.org.uk/
2. mailto:[email address]

Dear FOI Requests CGH,

This Data Impact Assessment only refers to the personal data of employees being stored for the purposes of implementing a permit scheme controlled by ANPR. There is no reference to the potential patient confidentiality issues of using ANPR & sending a PCN to the registered keeper of a vehicle parked by a patient or visitor as I detailed in my FOI request.

Please can you confirm that the issue of patient confidentiality was not considered when implementing this parking regime?

Please can you provide all emails & internal documents that detail the decision not to take account of patient confidentiality issues when implementing an ANPR system?

Yours sincerely,

Nigel Barker

FOI Requests CGH, East Suffolk and North Essex NHS Foundation Trust

Dear Nigel,

 

We are writing regarding your request for an internal review of your FOI
request reference number: 5122

 

Your internal review will be managed in accordance with the Trust’s FOI
Policy & Procedures.

 

If you are still dissatisfied with the handling of your request after
exhausting the Trust’s Internal Complaints Procedure, then you can contact
the Information Commissioner with details of your complaint using these
contact details:

 

Website:                              [1]www.ico.gov.uk  

Address:                              Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Telephone number:        08456 30 60 60

Fax number:                       01625 524510

 

The Trust aims to provide an answer to your complaint within 20 working
days of its receipt.

 

Regards,

 

Amy Witham

Information Governance Administrative Assistant

East Suffolk and North Essex NHS Foundation Trust

Based at: Ipswich Hospital

Email: [2][email address]

Telephone: 01473 702878 ext 1878

 

show quoted sections

FOI Requests CGH, East Suffolk and North Essex NHS Foundation Trust

Thank you for your request for Trust information:

 

Parking control by means of Automatic Number Plate Recognition (ANPR) is
being introduced at Colchester General Hospital. This will mean that for
infringement of parking regulations a Parking Charge Notice will be sent
to the Registered Keeper (RK) of the vehicle. In a hospital setting this
has serious implications for patient confidentiality. A patient who is the
driver of the vehicle may inadvertently incur a PCN but not wish the RK to
know that they attended the hospital e.g. domestic abuse or many other
reasons

 

This introduction of ANPR cameras means that patient confidentiality in
attending the hospital is now compromised. Please can you provide a copy
of the Data Protection Impact Assessment that has been undertaken prior to
the introduction of this scheme?

 

We received your request for an internal review as follows:

 

This Data Impact Assessment only refers to the personal data of employees
being stored for the purposes of implementing a permit scheme controlled
by ANPR. There is no reference to the potential patient confidentiality
issues of using ANPR & sending a PCN to the registered keeper of a vehicle
parked by a patient or visitor as I detailed in my FOI request.

 

Please can you confirm that the issue of patient confidentiality was not
considered when implementing this parking regime?

 

Please can you provide all emails & internal documents that detail the
decision not to take account of patient confidentiality issues when
implementing an ANPR system?

 

Your internal review has been completed in in accordance with Trust’s FOI
Policy and Procedures.

 

The Automatic Number Plate Recognition software is provided by ParkingEye
Ltd t/as Car Parking Partnership. Therefore, individuals entering the
visitor car park in their vehicle are sharing their data directly with
ParkingEye Ltd.

The data is not being handled by the Trust which is why it is not included
in the Data Protection Impact Assessment. Any Parking Charge Notices are
sent directly from ParkingEye Ltd, once again this personal data is not
handled by the Trust.

 

If you are still dissatisfied with the handling of your request now that
the Trust’s Complaints Procedure has been exhausted, then you can contact
the Information Commissioner with details of your complaint using these
contact details:

 

Website:                              [1]www.ico.gov.uk

Address:                              Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Telephone number:        08456 30 60 60

Fax number:                       01625 524510

 

We apologise for not being able to assist you any further with your
enquiry.

 

Regards,

 

Amy Witham

Information Governance Administrative Assistant

East Suffolk and North Essex NHS Foundation Trust

Based at: Ipswich Hospital

Email: [2][email address]

Telephone: 01473 702878 ext 1878

References

Visible links
1. http://www.ico.gov.uk/
2. mailto:[email address]

FOI Requests CGH, East Suffolk and North Essex NHS Foundation Trust

1 Attachment

Dear Mr Barker,

 

Thank you for your request for Trust information:

 

Parking control by means of Automatic Number Plate Recognition (ANPR) is
being introduced at Colchester General Hospital. This will mean that for
infringement of parking regulations a Parking Charge Notice will be sent
to the Registered Keeper (RK) of the vehicle. In a hospital setting this
has serious implications for patient confidentiality. A patient who is the
driver of the vehicle may inadvertently incur a PCN but not wish the RK to
know that they attended the hospital e.g. domestic abuse or many other
reasons

 

This introduction of ANPR cameras means that patient confidentiality in
attending the hospital is now compromised. Please can you provide a copy
of the Data Protection Impact Assessment that has been undertaken prior to
the introduction of this scheme?

 

We received your request for an internal review as follows:

 

This Data Impact Assessment only refers to the personal data of employees
being stored for the purposes of implementing a permit scheme controlled
by ANPR. There is no reference to the potential patient confidentiality
issues of using ANPR & sending a PCN to the registered keeper of a vehicle
parked by a patient or visitor as I detailed in my FOI request.

 

Please can you confirm that the issue of patient confidentiality was not
considered when implementing this parking regime?

 

Please can you provide all emails & internal documents that detail the
decision not to take account of patient confidentiality issues when
implementing an ANPR system?

 

Your internal review has been completed in in accordance with Trust’s FOI
Policy and Procedures.

 

We are pleased to inform you that the information will be released to you
as follows:

 

The Trust completed a Data Protection Impact Assessment when Automatic
Number Plate Recognition (ANPR) was introduced to Colchester Hospital in
October 2018, but this was more focussed on staff as their personal
details were being processed, as per our original response below:

 

The Automatic Number Plate Recognition software is provided by ParkingEye
Ltd t/as Car Parking Partnership. Therefore, individuals entering the
visitor car park in their vehicle are sharing their data directly with
ParkingEye Ltd. The data is not being handled by the Trust which is why it
is not included in the Data Protection Impact Assessment. Any Parking
Charge Notices are sent directly from ParkingEye Ltd, once again this
personal data is not handled by the Trust.

 

Therefore, we had no further information to release, as your request
concerned the visitor car parking aspect.

 

However, the Trust has re-considered your complaint, and even though the
visitor car registration number plate data is not processed by the Trust,
we have since included this in our data protection impact assessment.

 

Please find attached our updated data protection impact assessment.

 

If you have any queries about the enclosed information please contact us.

 

The Public Sector Information Regulations provide a framework for public
sector organisations to licence the re-use of their information.  Please
request a re-use licence in order to re-use the information. Without the
necessary permission, you can breach our copyright.

 

Brief extracts of any material may be reproduced without our permission,
under the “fair dealing” provisions of the Copyright, Designs and Patents
Act 1988 for the purposes of research for non-commercial purposes; private
study; criticism; review and news reporting. All are subject to an
acknowledgement of ourselves as the copyright owner.  For guidance notes
on a range of copyright issues, see the Office of Public Sector
Information web site.

 

If you remain dissatisfied with the handling of your request or complaint,
you have a right to appeal to the Information Commissioner at:

 

The Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Telephone: 08456 30 60 60 or 01625 54 57 45

Website: [1]www.ico.gov.uk

 

There is no charge for making an appeal.

 

We hope that we have been able to answer your query to your satisfaction
and that you find the information provided useful.

 

Regards,

 

Amy Witham

Freedom of Information Team

East Suffolk and North Essex NHS Foundation Trust

Email: [2][East Suffolk and North Essex NHS Foundation Trust request email]

 

This e-mail and any files transmitted with it are confidential. If you are
not the intended recipient, any reading, printing, storage, disclosure,
copying or any other action taken in respect of this e-mail is prohibited
and may be unlawful. If you are not the intended recipient, please notify
the sender immediately by using the reply function and then permanently
delete what you have received. Content of emails received by this Trust
will be subject to disclosure under the Freedom of Information Act 2000,
subject to the specified exemptions, including the The General Data
Protection Regulation (EU) 2016/679 and Caldicott Guardian principles.
East Suffolk and North Essex NHS Foundation Trust, Turner Road, Essex, CO4
5JL

References

Visible links
1. http://www.ico.gov.uk/
2. mailto:[East Suffolk and North Essex NHS Foundation Trust request email]