Schools livestreaming CCTV / IPTV off site in real time
Pippa King made this Freedom of Information request to Information Commissioner's Office
This request has been closed to new correspondence. Contact us if you think it should be reopened.
Dear Information Commissioner’s Office,
http://www.telegraph.co.uk/education/edu...
"However, in contrast to conventional CCTV cameras, parents and teachers are able to watch live feeds across dozens of the IP (internet protocol) cameras set up in classrooms, corridors and playgrounds to keep tabs on schoolchildren’s behaviour."
With regards to the above article detailing parents being able to watch children in school CCTV/IPTV in real time from off school premises on smart devices such as mobile telephones and tablet, please could you answer the following questions:
1) In this respect, what safeguards to protect children's data are put in place in schools, with regards to parents and potential other third parties being able to watch live feed in classrooms, to ensure children are not being viewed by possible people that may pose a risk to children?
(At the moment access to children in school is by accredited adults. This system would possibly give not just information about children, but potentially sensitive information about a child, for example about when a child attends a schools nurse or counselling session, relationships the child has, to unknown third parties in real time.)
2) What consents for pupils and parents are in place, for parents and potential other unknown third parties, to view other people’s children in real time on tablets and phones?
3) Is the ICO aware of the particular schools using this livestreaming CCTV/IPTV direct from school premises off site? If so what privacy impact assessments have been done in these schools? Footage (with audio) has the potential to be recorded, uploaded to websites, social media, etc. Please provide any particular reference to how a child’s privacy is impacted in this respect.
(The schools names have been withheld from the public due to “privacy reasons” (https://www.youtube.com/watch?v=VRAp8V6l... 32 seconds in) otherwise I could have asked the schools directly. Images and audio finding its way on to the internet could impact most severely on a child’s emotional wellbeing and safety.)
4) Please could you explain how this technology, livestreaming images (including audio) of children in real time to unknown third parties, does not breach the Data Protection Act?
5) As schools have CCTV cameras in toilets and other sensitive areas, how will the ICO ensure images from sensitive areas are not broadcast in real time off school premises to unknown third parties?
Thank you. I appreciate your time on this.
Yours faithfully,
Pippa King
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Dear Access ICO information,
Please can you conduct an internal review as to why this Freedom of Information request has not been answered.
Yours sincerely,
Pippa King
Thank you for contacting the Information Commissioner’s Office. We confirm
that we have received your correspondence.
If you have made a request for information held by the ICO we will contact
you as soon as possible if we need any further information to enable us to
answer your request. If we don't need any further information we will
respond to you within our published, and statutory, service levels. For
more information please visit [1]http://ico.org.uk/about_us/how_we_comply
.
If you have raised a new information rights concern - we aim to send you
an initial response and case reference number within 30 days.
If you are concerned about the way an organisation is handling your
personal information, we will not usually look into it unless you have
raised it with the organisation first. For more information please see our
webpage ‘raising a concern with an organisation’ (go to our homepage and
follow the link ‘for the public’). You can also call the number below.
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9 July 2014
Case Reference Number IRQ0547473
Dear Ms King
Thank you for your email of today about your email of 7 June.
I had discussed your email of 7 June with colleagues and it is my
administrative oversight that we have not provided any response to date -
I apologise for this.
As most of your email is an enquiry I have referred it to the relevant
team in our Strategic Liaison department for a response because they
are best placed to provide one - they will contact you shortly.
However, we have considered part 3 of your email under FOIA and it read as
follows:
"3) Is the ICO aware of the particular schools using this livestreaming
CCTV/IPTV direct from school premises off site? If so what privacy impact
assessments have been done in these schools? Footage (with audio) has the
potential to be recorded, uploaded to websites, social media, etc. Please
provide any particular reference to how a child’s privacy is impacted in
this respect."
We can confirm that we are not aware of the particular schools and have
not seen any privacy impact assessments. We therefore have no recorded
information to provide in response to your questions.
Whilst I appreciate this might not be the response you were hoping for I
hope it is of some assistance. I apologise again for the delay in our
response - the rest of your email will be responded to as an enquiry
shortly.
Based on this response, I don't intend to progress your request for an
internal review - but if you would like to progress it, please let me
know.
Yours sincerely
Helen Ward
Information Access Manager
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF
Tel: 0303 123 1113 Fax: 01625 524 510 Web: www.ico.org.uk
Dear Information Commissioner’s Office,
Thank you for your response. I do not require an internal inquiry but would be grateful to know the decision from the Strategic Liaison department on this.
Yours faithfully,
Pippa King
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Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
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Dear Ms King
Further to the response you have received in relation to your freedom of
information request, I am pleased to respond to your other general
enquiries in your original email.
Schools should ensure there are safeguards in place to protect the
personal data they process, and in your enquiry you identify a number of
privacy risks arising from the use of live stream CCTV and similar
technologies. When considering the use of such technologies, it is very
important that data controllers consider the problem that needs
addressing. Surveillance technologies in general shouldn’t be used merely
because they are relatively inexpensive or available, and any proposal to
use technologies which allow potentially vulnerable youngsters to be
viewed by a wider audience in what should be a safe and confident learning
environment needs very careful consideration. A data controller (which in
England, Wales and Northern Ireland is the school itself and in Scotland
is the local authority) should perform a privacy impact assessment,
following our [1]Conducting privacy impact assessments code of practice.
The data controller would need to consider the privacy issues involved
with using the technology and see if its use would be necessary and
proportionate and meet a pressing need which the data controller has
identified. We would suggest that they consider less privacy intrusive
methods of achieving this need where this is possible.
There may also be concern from staff that their activities will be
monitored, so any school considering whether to use such technologies
should also take our [2]Employment practices code, which discusses visual
and audio recording in the workplace, into account.
Any privacy impact assessment should involve an element of consultation
with those affected so that pupils, parents and staff are aware of the
proposal and their opinions taken into account.
In the event that a privacy impact assessment shows that the issues that
need addressing are weighty enough to justify this level of intrusion, we
would expect very strong safeguards to be put in place. For example,
consideration would have to be given to where cameras should be located,
whether continuous recording is necessary, who would be able to access and
view the system, and whether they would be able to record images. Would
there be technical measures in place to prevent recording? Our [3]CCTV
code of practice should be considered (see also our updated [4]draft
version for consultation, which closed on 1 July.)
The use of such technologies, if not properly considered and not used with
strong safeguards as described above, could potentially be in breach of
the Data Protection Act 1998 and at the very least would not be considered
good practice. As the response to your freedom of information request
says, the ICO is not aware of any particular schools using live stream
CCTV or similar, but we would of course respond to any concerns that are
subsequently brought to our attention.
Victoria Cetinkaya Senior Policy Officer (Public Services)
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF.
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF
Tel: 0303 123 1113 Fax: 01625 524 510 Web: www.ico.org.uk
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Pippa King left an annotation ()
I am not waiting for an internal review. This request is still waiting for information.