Dear Transport for London,

I write in request for information about Transport for London's use of ANPR (automated number plate recognition) cameras and derived data for uses other than the Congestion Charging scheme.

Please can you release to me the following information:

1) How many ANPR cameras does TfL operate which are not part of the Congestion Charge scheme?
2) Where are these cameras located?
3) What is the data gathered from non-CC ANPR cameras used for?
4) What are the operating principles used by TfL for managing data gathered from the non-CC ANPR cameras?
5) How long does TfL retain data from the non-CC ANPR cameras, and what format is this data stored as? (e.g. License plate numbers, plate images, whole vehicle images etc.) (With the understanding that this information may be covered by the answer to question 4.)
6) Who can access this data within TfL?
7) What other agencies or organisations outside TfL can access this data?
8) Which agencies or organisations outside TfL have accessed this data within (a) 2014, (b) 2013, (c) 2012, where such information is available?
9) Are non-CC ANPR cameras also covered by the Certificate of Access provided for the Metropolitan Police for access to the CC ANPR camera data, and if so, is this the non-CC ANPR routinely transferred with CC data to the Metropolitan Police?
10) How is the non-CC ANPR data stored separately by TfL, if this is the case, or are the two datasets stored together?

If you have any queries about any of these questions which may assist you in generating your response, please do not hesitate to contact me. I look forward to your reply.

Yours faithfully,

James Bridle

FOI, Transport for London

Dear Mr Bridle

 

Our ref:  FOI-1286-1415

 

Thank you for your email received on 4 November 2014 asking for
information about ANPR cameras with uses other than Congestion Charging.

 

Your request will be processed in accordance with the requirements of the
Freedom of Information Act and our information access policy.

 

A response will be provided to you by 3 December 2014.

 

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

 

 

Yours sincerely

 

 

Graham Hurt

FOI Case Officer

 

FOI Case Management Team

General Counsel

Transport for London

 

 

 

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References

Visible links
1. http://www.tfl.gov.uk/corporate/about-tfl/

Dear Mr Hurt,

Please note that your response due by 3 December 2014 is now overdue. Under the Freedom of Information Act you are required to give notice if the response will be delayed beyond the stated period, and no correspondence has been received since the 4th November. I look forward to receiving your full response.

Yours sincerely,

James Bridle

FOI, Transport for London

Dear Mr Bridle
 
Our ref:  FOI-1286-1415
 
Thank you for your email received on 4 November 2014 asking for
information about ANPR cameras with uses other than Congestion Charging.
 
Your request has been considered in accordance with the requirements of
the Freedom of Information (FOI) Act and our information access policy. 
 
Because of the complexity of your request we have not been able to resolve
your request within the statutory 20 working days. Please accept my
apologies for this delay.
 
We are continuing to work on your request and will respond as soon as
possible.
 
In the meantime, we thank you for your patience.
 
Please see the attached information sheet for details of your right to
appeal.
 
Yours sincerely
 
 
Graham Hurt
FOI Case Officer
 
FOI Case Management Team
General Counsel
Transport for London
 
 
 
 

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References

Visible links
1. http://www.tfl.gov.uk/corporate/about-tfl/

FOI, Transport for London

2 Attachments

Dear Mr Bridle

 

Our ref:  FOI-1286-1415

 

Thank you for your email received on 4 November 2014 asking for
information about ANPR cameras with uses other than Congestion Charging.
Please accept my apologies for the delay in responding.

 

Your request has been considered under the requirements of the
Environmental Information Regulations (EIR) and our information access
policy. I can confirm that we do hold the information you require.

 

1)    How many ANPR cameras does TfL operate which are not part of the
Congestion Charge scheme?

 

TfL operate and maintain a total of 1,517 ANPR cameras. 646 of these
cameras are for the enforcement and administration of the Congestion
Charge, 342 of these cameras are for the enforcement of the Low Emission
Zone, 498 of these cameras are for monitoring and modelling purposes and
there are 31 average speed cameras for speed enforcement purposes which
use ANPR operating in London.

 

2)    Where are these cameras located?

 

The attached spreadsheet provides the locations of the Congestion Charge
and Monitoring Cameras.

 

The average speed cameras operated by TfL are located along the A13 in
Barking and Newham.  The precise locations can be identified from looking
at the London Datastore via the following link:
[1]http://data.london.gov.uk/

 

In accordance with the EIR, we are not obliged to supply the location of
the LEZ cameras as this is subject to a statutory exception to the right
of access to information under regulation 12(5)(g) where disclosure would
have adverse impacts on the environment.

 

The aim of the LEZ is to improve air quality in London by deterring the
most polluting vehicles from driving in the area. It is designed to reduce
levels of pollutants that have been proven to damage human health, by
causing asthma and other respiratory illnesses. The LEZ covers the whole
of Greater London, within the M25.  Significantly, unlike the Central
London Congestion Charging zone, it is not possible to have cameras on
every single entry and exit point, due to the sheer scale of the zone.

 

Disclosures under EIR are considered as a disclosure to the ‘public at
large’. Providing specific camera locations would encourage non compliance
with the Low Emission Zone by encouraging drivers to deliberately seek out
those roads which are known not to be covered by an enforcement camera.

 

The LEZ is designed to be a deterrent. This is reflected in the level of
the daily charge of up to £200 and the Penalty Charge of up to £1000. If
vehicle owners know they can avoid the charge by avoiding the cameras
themselves, it removes the incentive to adapt their vehicle to meet the
required emissions standards. This in turn will affect the necessary level
of improvement in air quality.

 

The Mayor has a statutory duty to take steps towards achieving Government
air quality objectives, and reducing pollutants that are harmful to human
health - the LEZ forms a key part of this strategy for London. Disclosure
of the camera locations would frustrate meeting those objectives.

 

The use of this exemption is subject to an assessment of the public
interest in relation to the disclosure of the information concerned. The
LEZ is a measure that is designed to improve the environment for everyone.
However, in this case, disclosure of the individual camera locations will
in itself defeat the purpose of the LEZ, by encouraging non compliance. A
significant amount of boundary information is already in the public domain
– by way of detailed maps and a postcode location checker – that enables
drivers to know the exact areas covered by the LEZ. Therefore, in this
instance we feel that balance lies in favour of withholding the
information.

  

3)    What is the data gathered from non-CC ANPR cameras used for?

 

The ANPR data gathered from the Low Emission Zone Cameras is used for the
administration and enforcement of the Low Emission Zone Scheme. The data
gathered from the Congestion Charge Cameras is used for the administration
and enforcement of the Congestion Charge Scheme and the Low Emission Zone
Scheme.

Data gathered from all TfL cameras (Congestion Charge, Low Emission Zone
and Monitoring Cameras) is used by TfL to monitor and measure network
performance and journey times and for traffic modelling purposes.

 

We also share this data with the Metropolitan Police Service (MPS) for
the purpose of safeguarding national security.  The Home Secretary has
signed a Certificate confirming that TfL, and the MPS are exempt from
certain provisions of the Data Protection Act 1998 for the purpose of
providing the MPS with real time access to the information captured by the
network of cameras used for the operation of the Congestion Charge and the
Low Emission zone.

 

The data from a subset of the TfL ANPR Cameras is shared with
TrafficMaster as part of a data sharing agreement and this is done for the
purpose of providing real-time journey information. Please note that this
data is anonymised before sharing.  The speed cameras are used to
determine the average speed of vehicles travelling between camera
locations.  These cameras record the date and time stamp of vehicles
passing and this is used to calculate the average vehicle speed of
vehicles between cameras and to enforce speed restrictions.

 

4)    What are the operating principles used by TfL for managing data
gathered from the non-CC ANPR cameras?

 

The data captured by the LEZ Cameras is handled in the same way as the
data captured by the CC Cameras. All Vehicle Registration Marks (‘number
plates’) captured by the monitoring cameras are automatically anonymised
(irreversibly ‘hashed’ using an algorithm) which means that ANPR data
cannot be linked to an actual vehicle. All systems that process the
anonymised ANPR data are secure and controlled via role-based access
permissions and require a unique a username and password to log in.
 Access is recorded for audit and monitoring purposes.

 

The average speed cameras on the A13 are for enforcement purposes. The
police operate this system and are responsible for issuing penalties as
appropriate.  TfL do not retain any of the enforcement data which is
handled by the Metropolitan Police Service.

 

5)    How long does TfL retain data from the non-CC ANPR cameras, and what
format is this data stored as? (e.g. License plate numbers, plate images,
whole vehicle images etc.) (With the understanding that this information
may be covered by the answer to question 4.

 

Anonymised Vehicle Registration Mark data is retained within the TfL
systems for a period of 3 years before being archived. Data is stored on
secure servers in a secure location and is accessible only to
appointed/authorised staff as described above in the answer to Question 4.

 

Data from the Low Emission Zone Cameras is also stored for the purpose of
administering and enforcing the Low Emission Zone Scheme. Data is stored
in the form of Vehicle Registration Marks and their associated images
(plate patches and vehicle images).

 

Data from ANPR Speed cameras is not retained by TfL. The enforcement data
is handled by the Metropolitan Police Service.

 

6)    Who can access this data within TfL?

 

Access to the TfL systems and the ANPR data within them is controlled on a
role-based permissions basis and by  unique username and password. Only
those staff that require access as part of their role are provided with
usernames and passwords.

 

7)    What other agencies or organisations outside TfL can access this
data?

 

As referenced in answer to Question 3), ANPR data captured from TfL
cameras operated for the purpose of the Congestion Charge, Low Emission
Zone and traffic monitoring  is shared with the Metropolitan Police.  Data
from selected cameras is also shared with TrafficMaster, but this data is
anonymised before being shared. 

 

Personal data captured by TfL ANPR cameras may be shared by TfL when a
valid reason to obtain the data under the Data Protection Act 1998 is
provided by the organisation making the request. Such requests are dealt
with on a strictly case-by-case basis. TfL receives requests for ANPR from
polices forces and other statutory law enforcement agencies.

 

TfL has a contract with a third party service provider which provides the
majority of the administration and 'back office' services required for the
day-to-day operation of the Congestion Charge and Low Emission Zone.

 

8)    Which agencies or organisations outside TfL have accessed this data
within (a) 2014, (b) 2013, (c) 2012, where such information is available?

 

The Metropolitan Police and TrafficMaster currently receive data, as
described in Questions 3) and 7), in 2012, 2013 and 2014. Additionally,
the Metropolitan Police have made enquiries under Section 29 of the Data
Protection Act .

 

9)   Are non-CC ANPR cameras also covered by the Certificate of Access
provided for the Metropolitan Police for access to the CC ANPR camera
data, and if so, is this the non-CC ANPR routinely transferred with CC
data to the Metropolitan Police?

 

The Certificate signed by the Home Secretary under section 28 of the Data
Protection Act 1998 allows TfL to disclose data from any  of its ANPR
cameras to the MPS.

 

10) How is the non-CC ANPR data stored separately by TfL, if this is the
case, or are the two datasets stored together?

 

Data from all the TfL cameras is consolidated and anonymised automatically
before being transferred to TfL systems. The anonymised data is then is
stored by two TfL systems – the London Vehicle Analysis Tool (LVAT) for
the purpose of Traffic Modelling and the London Congestion Analysis
Program (LCAP) for monitoring and measuring network performance. All
camera data is stored together.

 

Further information is available at:
[2]www.tfl.gov.uk/corporate/privacy-and-cookies/cctv and
[3]http://www.tfl.gov.uk/corporate/privacy-...

 

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.

 

If you are not satisfied with this response please see the attached
information sheet for details of your right to appeal.

 

Yours sincerely

 

Graham Hurt

 

FOI Case Officer

FOI Case Management Team

General Counsel

Transport for London

 

 

 

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Dear Mr Hurt,

Thank you very much for response to my request, which contains all of the information I requested, where not exempt. I have one request for clarification, in what appears to be a contradiction within the release.

In your answer to Question 4, you state:

"The data captured by the LEZ Cameras is handled in the same way as the data captured by the CC Cameras. All Vehicle Registration Marks (‘number plates’) captured by the monitoring cameras are automatically anonymised (irreversibly ‘hashed’ using an algorithm) which means that ANPR data cannot be linked to an actual vehicle. All systems that process the anonymised ANPR data are secure and controlled via role-based access permissions and require a unique a username and password to log in. Access is recorded for audit and monitoring purposes."

I'm not sure that this can be strictly accurate, as LEZ and CC camera data is used by TfL to issue penalty notices, and therefore cannot be anonymised immediately in the way you describe, because this means that offenders cannot be identified.In addition, truly anonymised data would not be useful for traffic information, as there would be no way of linking different vehicles at different points in their journey. Please could you clarify the length of time identifying and anonymised data is stored for, and what the anonymised data is used for at a later date.

Yours sincerely,

James Bridle

FOI, Transport for London

Dear Mr Bridle

 

Thank you for your email. I have noted your query with regards to our
answer to Question 4.

 

I am currently investigating this and will come back to you as soon as
possible.

 

Kind regards

 

Graham Hurt

 

FOI Case Officer

FOI Case Management Team

General Counsel

Transport for London

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References

Visible links
1. http://www.tfl.gov.uk/corporate/about-tfl/

FOI, Transport for London

1 Attachment

Dear Mr Bridle

Thank you for your email of 10 December 2014. I apologise if our response to question 4 of your original request was unclear, and hope I can now clarify this point.

Data captured from the LEZ and CC Cameras is sent to the London Road User Charging (LRUC) Systems to allow the effective administration and enforcement of both the CC and LEZ schemes. For clarity this data is not anonymised in anyway and data is retained in accordance with the data retention rules by the LRUC Systems.

Data captured from the CC and LEZ cameras and the monitoring cameras is also sent to TfL systems for the purpose of monitoring and measuring network performance and journey times and for traffic modelling purposes. Before being sent to the TfL Systems, which are different to the LRUC Systems, the data is automatically anonymised. This allows us to identify captures of the same vehicle, to allow analysis of vehicle movements, without recording the VRM of the vehicle and this anonymised (Hashed) Vehicle Registration Mark data is retained within the TfL Systems for a period of 3 years before being archived.

I hope this answers your query. If you are not satisfied with this response please see the attached information sheet for details of your right to appeal.

Yours sincerely

Graham Hurt

FOI Case Officer
FOI Case Management Team
General Counsel
Transport for London

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Dear Mr Hurt,

Thank you for your response. I appreciate the clarification, and now consider this request closed.

Yours sincerely,

James Bridle

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