CCTV Subject Access Request

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CCTV Subject Access Request

Post by RJSRdg » 14 Feb 2018, 08:20

After the Park Challenge, I made a Subject Access Request (under Section 7 of the Data Protection Act) to TfL for the CCTV footage of my attempt at the challenge, partly to give me a record and partly to assess its suitability as corroborating evidence if I ever attempt the FNC GWR.

I originally asked for footage of my visits to all 24 Park stations plus 6 changes.

The Data Officer replied at first to ask if I could refine the request, as some stations have over 300 cameras(!) to check, and would I be happy with just the footage from platforms and going through the barriers. I agreed to this, even though strictly speaking a data subject is entitled to ALL the footage TfL hold on them.

The Data Officer replied again to say that in order to retrieve the information, they need to send a police officer to each of the stations involved (the footage is not stored centrally), and could I reduce the list of stations to around 10.

I replied that as an Information Rights Officer myself (!) I had no wish to make unnecessary work for him so I would go with the 10. He replied and said he would ask for 15!

On Saturday I received a CD containing the footage (it had been waiting at the RM collection centre for a few days). On viewing the footage I can make the following observations:

1) The footage contains redactions. In some cases, if the station is quiet, it may be unredacted. In other cases if there are isolated passengers, their faces may be redacted (de-focused). In busier stations the whole image may be de-focused apart from the data subject (however this is a little hit and miss, some of the less busy stations are also redacted.

2) Although the footage contains a timestamp, it is not labelled as to which station it is from, nor are platform roundels usually visible (as they are perpendicular to the direction of the cameras). It is possible to make out a roundel at Westbourne Park, but this has been redacted!

3) Usefully though, the footage has usually been supplied up to the moment the train leaves rather from when I board it.

So, what would I recommend to people wanting to use CCTV footage as supporting evidence?

1) Be realistic - do NOT ask for all 270 stations! Try to limit it to around a dozen (start, finish and any where you made a change so quickly you were unable to photograph a roundel).

2) Ask the data officer to release the footage up to the moment the train starts to move (at least for the starting station).

3) Ask the data officer to include a list of the footage supplied in their covering letter (e.g 'Chesham 05:10-05:15').

Note also that in May the Data Protection Act will be replaced by the General Data Protection Regulations which will have two impacts:

* TfL will be able to charge a variable fee for the footage rather than a set £10 fee.
* The statutory time for TfL to return the data will be reduced from 40 days to 20 working days - this may impact the amount of data they offer to release.

When I get time, I will edit the footage (some of it is out of order, and other bits are from stations where I had a long wait) and post it for you to look at.
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Re: CCTV Subject Access Request

Post by ITFCShirts » 28 Feb 2018, 22:36

This is really interesting. I was planning on testing this if my FNC attempt had come in on track. I had planned to ask for the key interchanges/End of Lines/Start and Finish. Be interested to see what GWR would make of not having every attempt/every station though!

Also, being part of the GDPR committee at work, it will be interesting to see what changes they make. I wasn't sure in the spirit of FOI they could limit you (except within reason), and that GDPR would demand that they had to give you all the data (because it belongs to you), but as you say, subject to how much TFL decides is a reasonable charge for such an exercise. Sounds like another GWR paid judges ploy....

Definitely would like to see some of the image/video snapshots though!

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