PRIVACY IMPACT ASSESSMENT

CONDUCTING A PRIVACY IMPACT ASSESSMENT ON

SURVEILLANCE CAMERA SYSTEMS (CCTV)

1
Principle 2 of the surveillance camera code of practice states that the use of a surveillance camera
system must take into account the effect on individuals and their privacy, with regular reviews to ensure
its use remains justified. The best way to ensure this is by conducting a privacy impact assessment
before the system is installed and when a new camera is being added on to an existing system. This will
assist in managing any privacy issues the use of the surveillance system might have.

A privacy impact assessment (PIA) enables operators to unpick risks to compliance with the Data
Protection Act 1988 and the Human Rights Act 1998. The PIA should initially consider the pressing need
that the system seeks to address and the impact that recording may have on individual’s privacy. It is
important to decide whether the proposed system can be justified as proportionate to the reason it is
needed.

In undertaking a privacy impact assessment you must take into consideration your obligations under the
Data Protection Act 1998 and follow the guidance provided in the Information Commissioner’s Office’s
(ICO) CCTV code of practice.

This privacy impact assessment template is specifically for those organisations that must have regard to
the surveillance camera code of practice under the Protection of Freedoms Act 2012. It also helps
organisations to address their data protection and human rights obligations.

A PIA does not always have to be conducted as a completely separate exercise and it can be
incorporated into project planning or other management and review activities.

In deciding whether to conduct a PIA and its scope, consideration must be given to the nature and scope
of the surveillance camera activities and their potential to impact on the privacy rights of individuals.

A PIA should be considered when you are reviewing your surveillance camera systems and when you
are considering introducing new technology connected to them.

A privacy impact assessment should be considered when any of the following apply:
 When you are introducing a new surveillance camera system.
 If you are considering introducing new or additional technology that may affect privacy
(e.g. automatic number plate recognition (ANPR), body worn cameras, unmanned aerial vehicles
(drones), megapixel or multi sensor very high resolution cameras).
 When you are changing the location or field of view of a camera or other such change that may raise
privacy concerns.
 When you are reviewing your system to ensure that it is still justified. It is recommended that you
review your system annually (see ICO CCTV Code of Practice and Surveillance Camera Code of
Practice Principle 10).
 If you are considering the capture of an additional identifier such as vehicle registration mark to
enable ANPR.
 The activity or change will engage heightened privacy concerns such as voice recording and
biometric recognition such as facial and gait recognition.
 If your system involves any form of cross referencing to other collections of personal information.
 If your system involves more than one company or agency undertaking activities either on your
behalf or in their own right.
 When you change the way in which the recorded images and information is handled, used or
disclosed.
 When you increase the area captured by your surveillance camera system.
 When you change or add an end user or recipient for the recorded information or information derived
from it.

Conducting a Privacy Impact Assessment on surveillance camera systems (CCTV) (07.17) 2

Description of proposed surveillance camera system

Provide an overview of the proposed surveillance camera system

This should include the following information:
 An outline of the problem the surveillance camera system is trying to resolve.
 Why a surveillance camera system is considered to be the most effective way to solve the issues.
 How the surveillance camera system will be used to address the problem (identified above).
 How success will be measured (i.e. evaluation: reduction in crime, reduction of fear, increased
detection etc).

In addition, consideration must be given to proportionality, legality, accountability and necessity.

Any interference by a public authority of an individual’s rights must be justified.

Therefore the following questions must be considered as part of a PIA:

 Is the surveillance activity established on a proper legal basis and is it undertaken in accordance with
the law?
 Is the surveillance activity necessary to address a pressing need, such as public safety, crime
prevention or national security?
 Is it justified in the circumstances?
 Is it proportionate to the problem that it is designed to deal with?

If the answer to any of these questions is no, then the use of surveillance cameras is not
appropriate.

Otherwise please proceed to complete the template below.

Conducting a Privacy Impact Assessment on surveillance camera systems (CCTV) (07.17) 3

PRIVACY IMPACT ASSESSMENT TEMPLATE
The privacy impact assessment template comprises two parts.

Level one considers the general details of the surveillance camera system and supporting business
processes, level two considers the specific implications for the installation and use of cameras

Template – Level One

Location of surveillance camera system being assessed:
Hartlepool Public Space CCTV system

Date of assessment 26.04.19

Review date 26.04.20

Name of person responsible Nicholas Stone

Data Protection Act 1998 and Surveillance Camera Code of Practice 2013

1. What is the organisation’s purpose for using the surveillance camera system and what are the
issues that the system aims to address? Evidence should be provided which should include relevant
available information, such as crime statistics for the previous 12 months, the type, location, times and
numbers of crime offences, housing issues relevant at the time, community issues relevant at the time
and any environment issues relevant at the time.
(a) Prevention and Detection of Crime and Disorder
(b) Apprehension and Prosecution of Offenders
(c) Protection and Safeguarding of Vulnerable Persons and Victims
(d) Protection of National Security
(e) Protection of Public Safety
(f) Protection of Public Health or Morals
(g) Public Reassurance
(h) The Protection of the Rights and Freedoms of Others
(i) Protection of Hartlepool Borough Council assets and personnel
(j) Management of public space areas and events
(k) Assisting Hartlepool Borough Council, Cleveland Police and other Statutory and Enforcement
Agencies in carrying out their statutory, and investigatory, regulatory, licensing, and
enforcement duties, (including the administration of their personnel)
(l) Assisting in Traffic Management and in Highway and Environmental Enforcement
(m) Providing assistance with civil claims
(n) Providing assistance and reassurance to the public in emergency situations
(o) Providing assistance to Emergency Services and Emergency Planning in the management of
emergency incidents

2. Can a surveillance camera technology realistically deliver these benefits? State why the use of
surveillance cameras will deliver these benefits in practice including evidence to justify why that would be
likely to be the case.
The use of CCTV:
• Allows for the monitoring of public areas at risk of crime and disorder on a 24/7 basis.

• Allows the collection of independent evidence for use in civil and criminal matters.

Conducting a Privacy Impact Assessment on surveillance camera systems (CCTV) (07.17) 4

• Assists Hartlepool Borough Council, Cleveland Police, and other Statutory and Enforcement
Agencies in carrying out their statutory, and regulatory, investigatory and enforcement duties.

• Assists and enhances the work of the Emergency Services and Emergency Planning in a more
effective operational management of incidents.

3. What are the views of those who will be under surveillance? Please outline the main comments
from the public resulting from your consultation – some consultation should be undertaken in the area
being considered for a surveillance camera scheme. This can often be achieved by existing local
consultation mechanisms such as local area committees, police beat meetings; but, if necessary
depending on the privacy intrusion of the surveillance in question, other mechanisms could be
considered such as face to face interviews, questionnaires being sent to residents/businesses and
addressing focus groups, crime & disorder partnerships and community forums.
Hartlepool Borough Council’s Public Space CCTV has wide public support from local residents and
elected members.

In 2008 Hartlepool Borough Council's Viewpoint Survey Panel of 1000 local residents showed that 93%
of respondants were supportive of the Public Space CCTV system, and that 50% of respondants said
that CCTV cameras made then feel safer.

In 2017, 225 questionnaires were sent out under a consulation for 3 new Public Space CCTV cameras.
A total of 15 questionnaires were returned - 14 were in favour and 1 was against the proposal. (due to a
concern over house prices)

4. Have other less privacy-intrusive solutions such as improved lighting been considered? There
is a need to consider other options prior to the use of cameras. For example, could improved lighting
deliver the same benefit? Does the camera operation need to be 24/7? Where these types of restrictions
have been considered, provide reasons for not adopting them and opting to use surveillance cameras as
specified.
Yes. CCTV cameras are not installed by Hartlepool Borough Council unless other actions have first
been either considered, or attempted over a period of time to resolve or reduce the problem. What
actions are taken will depend on the location, the circumstances of the issue(s), the risk of harm, and
the vulnerability and the wishes of victims. Action considered may potentially include; improved lighting,
extra police patrols, extra youth outreach patrols, extra security officer patrols, crime prevention and
target hardening measures, encouraging public reporting of problems, restorative interventions, and the
diversion, support, treatment, and education of perpetrators, along with enforcement actions.

5. What are the benefits to be gained from using surveillance cameras? Give specific reasons why
this is necessary compared to other alternatives. Consider if there is a specific need to prevent/detect
crime in the area. Consider if there would be a need to reduce the fear of crime in the area, and be
prepared to evaluate.
(a) Crime prevention
(b) Reduction in crime and disorder
(c) Reduction in substance misuse
(d) Decreased costs to Public Services
(e) Increased guilty pleas of offenders
(f) Increased safeguarding of victims, vulnerable persons and vulnerable localities from harm
(g) Decreased fear of crime by local residents
(h) Increased confidence in public services
(i) Improved reputation of Hartlepool Borough
(j) Improved management of emergency incidents by Emergency Services and Emergency
Planning

Conducting a Privacy Impact Assessment on surveillance camera systems (CCTV) (07.17) 5

6. What are the privacy issues arising from this surveillance camera system? State the main
privacy issues relating to this particular system. For example, the extent of information recorded, whether
it will be only on those who are suspects or include those who are not, concerns arising from its use,
retention and disclosure, likely expectations of those under surveillance and impact on their behaviour,
level of intrusion into their lives, effects on privacy if safeguards are not effective.
The CCTV system records 24 hours a day and retains images for 31 days from the Council's network of
Public Space CCTV cameras. Images will consist of persons in public places using none covert CCTV
cameras. This will include members of the general public and targeted individuals and their acitivities.
The public are advised of CCTV cameras by appropriate signage.

The potential privacy issues are:

(a) The collection, handling and retention of personal data
(b) The collection, handling and retention of sensitive personal data
(c) Risk of excessive, inappropriate or illegal viewing or monitoring or data release
(d) Risk of accidential data loss

7. Have any privacy by design features been adopted to reduce privacy intrusion? Could any
features be introduced as enhancements? State the privacy enhancing technical and other features
that have been identified, considered and accepted or rejected. For example, has consideration been
given to the use of technical measures to limit the acquisition of images, such as privacy zones installed
on cameras that overlook residential properties, etc? If these have not been adopted, provide a reason.
To ensure the security and control of data the CCTV system has the following safeguards:

(a) The CCTV Centre is a restricted access and secure facility which is not open to the public.

(b) No unauthorised audio or video viewing, transmitting or recording equipment is permitted in the
Control Room or Viewing Suite. Warning signs reinforce this message.

(c) The Control Room and Viewing Suites are physically designed to prevent unauthorised persons
accessing, seeing, overhearing or accessing centre operations, systems or data.

(d) CCTV operators have received training on:

- Data Protection and Human Rights
- Use and release of CCTV footage
- Use of Radio Communications
- Access Control
- CCTV surveillance

(e) The release of all images to Agencies is subject to approval by a CCTV operator and the completion
of a CCTV Images Disclosure Form.

(f) The release of all images to the Public is subject to approval by the Council’s Data Protection Officer.

(g) CCTV operators are Council employees subject to Contract of Employment, Corporate Code of
Conduct, Data Protection and Information Governance Policies.

(h) CCTV operators have signed a Confidentiality Agreement.

(i) CCTV operators have been subject to Enhanced Disclosure and Baring (DBS) checks, and have
cleared None Police Personnel Vetting Level 2 through Cleveland Police.

(j) All electronic documents are stored in a secure I.T folder on the Council’s servers.

(k) All paper documents are stored in the secure CCTV Control Room.

(l) All staff have a secure e-mail account and have received training regarding its use.

Conducting a Privacy Impact Assessment on surveillance camera systems (CCTV) (07.17) 6

(m) All staff have been provided with training on the use, storage, disclosure and disposal of all
confidential documents.

(n) All paper documents are disposed of by staff by shredding using an onsite High Security Micro
Shredder. (DIN Level 4)

(o) All centre physical I.T assets and data baring media are disposed of in accordance with ISO
27001:2013 through the Council’s secure disposal processes.

(p) The CCTV Control Room, Viewing Suite and CCTV server room are subject to internal CCTV
cameras which record on a 24/7 basis for audit and security purposes. Staff have no ability to stop, alter
or delete this CCTV recording.

(q) All Radio communications are by secure Radio links.

(r) All Police Airwave Radio communications are recorded by Cleveland Police.

(s) Images are transmitted via the Council’s own secure internal optical fibre network, a secure Virtual
Private Network (VPN) on the Council’s I.T network, or by Council owned secure wireless radio links.

(t) The CCTV Control Matrix and associated recording servers are stored in a secure server room
onsite at the CCTV Centre. Access is restricted to the Centre Manager and authorised Council staff and
contractors.

(u) All CCTV servers automatically delete images after 31 days after which no images are retained by
the Council.

(v) The CCTV Control system and its associated recording servers are password protected and have
built in audit programs to track all activity undertaken.

The CCTV system does not make use of any privacy zones. The measures listed above remove the
need for them.

8. What organisations will be using the CCTV images and where is data controller responsibility
under the Data Protection Act 1998? List the organisation(s) that will use the data derived from the
camera system and identify their responsibilities, giving the name of the data controller(s). Specify any
data sharing agreements you have with these organisations.
The Council’s Data Protection Officer is responsible for all data held by the Council.

In addition the CCTV Centre Manager and CCTV operators are also responsible for the security of any
data held by the CCTV Centre.

The following persons/organisations may obtain/use images held by the Council:

(a) Data Subjects - personal use
(b) Cleveland Police - investigation of complaints
(c) Crown Prosecution Service - prosecution of criminal suspects
(d) Courts Service (i.e. County, Magistrates, Crown) - hearing of civil and criminal cases
(e) Any Statutory or Enforcement Organisation carrying out their statutory, or investigatory,
regulatory, licensing, or enforcement duties, (including the administration of their personnel)
(f) Insurance Companies - on behalf of clients involed in civil and criminal cases
(g) Solicitors Chambers - on behalf of clients involved in civil and criminal cases

An information sharing agreement exists between members of the Safer Hartlepool Partnership.

Conducting a Privacy Impact Assessment on surveillance camera systems (CCTV) (07.17) 7

9. Do the images need to be able to identify individuals, or could the scheme use other images
not capable of identifying individuals? Explain why images that can identify people are necessary in
practice. For example cameras deployed for the purpose of ensuring traffic flows freely in a town centre
may not need to be able to record images of identifiable individuals, whereas cameras justified on the
basis of dealing with problems reflected in documents showing the current crime hotspots may need to
capture images of identifiable individuals.
Yes. The CCTV system and all of its CCTV cameras are designed to be able to meet 5 levels of the
CAST Standard:

- Monitor and Control

- Detect
- Observe
- Recognise
- Identify

The majority of the Council’s cameras are moveable (PTZ) - pan, tilt, zoom cameras which have the
ability to zoom in from a distance and can be used to obtain the identity of an individual as required.

The CCTV system records images in either high quality or HD depending on the camera involved.

All cameras have the potential to be used for all purposes previously set out in question 1.

10. Will the surveillance camera equipment being installed and the system of work being adopted
be sustainable? Is there sufficient funding for the scheme? Consideration should be given as to how
the revenue costs (e.g. monitoring, transmission) are going to be met, to ensure that the system remains
effective and justified over its projected lifespan. State how long funding has been secured for.
The CCTV system has an ongoing sustainable revenue budget through mainstream Council funding.
This is supplemented by a small income from the provision of out of hours services to internal and
external clients.

Any new CCTV cameras added to the CCTV system must have an associated revenue budget
approved before they are installed.

11. Will the particular system/equipment being considered deliver the desired benefit now and in
the future? State how the system will continue to meet current and future needs, including your review
policy and how you will ensure that your system is up to date. It is recommended that you conduct a
minimum of an annual review of your system in order to consider whether it is still appropriate and able
to meet the specified need it was set up to deliver.
Since 2017 the Council has replaced and upgraded its Town Centre and Night Time Economy area
CCTV cameras with HD cameras, and also built a new CCTV Control Centre. This included the
replacement of all CCTV Centre control and recording equipment.

All new CCTV equipment procured is designed for future compatibility under the ONVIF scheme
standard.

The CCTV service has a mainstream revenue maintenance budget for the repair of CCTV equipment.

An annual review is carried out of the CCTV Service and its cameras. This consists of a review of the
performance of the service and its cameras. Where any CCTV camera is shown to no longer be
necessary it is decommissioned. Due to this in 2013 the Council decommissioned 12 CCTV cameras
from its CCTV system.

Conducting a Privacy Impact Assessment on surveillance camera systems (CCTV) (07.17) 8

12. What future demands may arise for wider use of images and how will these be addressed?
Consider whether it is possible that the images from the surveillance camera scheme will be used for
any other purpose (e.g. traffic monitoring, enforcement, ANPR) in future and how such possibilities will
be addressed. Will the cameras have a future dual function?
Not applicable. All cameras already have the potential to be used for all purposes as previously set out
in question 1.

Human Rights Act 1998

Section 6(1) of the Human Rights Act 1998 (HRA) provides that it is unlawful for a public authority to act
in a way which is contrary to the rights guaranteed by the European Convention on Human Rights.
Therefore in addition to the above, if you are a public authority, you must make sure that your system
complies with the requirements under the HRA.

1. Is the system established on a proper legal basis and is it operated in accordance with the
law? State the statutory or other powers which provides the basis for the activity.
The CCTV system was established by Hartlepool Borough Council under:

(a) Section 17 of the Crime and Disorder Act 1998. This makes it the duty of an Authority to exercise its
various functions with due regard to the likely effect of the exercise of those functions on; crime and
disorder in its area and; the misuse of drugs, alcohol and other substances; and re-offending in its area.

(b) Section 163 of the Criminal Justice and Public Order Act 1994. This enables a local authority to
promote the prevention of crime or the welfare of the victims of crime by providing apparatus for
recording visual images of events occurring on any land in their area.

The use of CCTV is designed to assist the Council in tackling these issues and the CCTV system
operates within the relevant legislation and Codes of Practice.

2. Is the system necessary to address a pressing need, such as public safety, crime prevention
or national security? Articulate the problem and why this is a pressing concern.
Yes. The CCTV system is necessary for Public Safety, Crime Prevention and National Security
purposes.

Hartlepool Borough is the smallest unitary authority in the North East England region and the third
smallest in the country and includes of some of the most disadvantaged areas in England.

Due to this Hartlepool Borough experiences higher than average rates of crime, anti-social behaviour
and substance misuse.

Hartlepool Borough also includes the Port of Hartlepool, Hartlepool Nuclear Power Station, and
Middleton Grange Shopping Centre.

The Council has invested in the use of monitored Public Space CCTV to assist in meeting its statutory
requirements to reduce crime, disorder, substance misuse, reduce re-offending, protect public buildings
and areas, improve public safety and confidence, and to assist the Emergency Services and
Emergency Planning in identifying and managing emergency incidents.

3. Is it justified in the circumstances? Provide the justification.

Yes. Hartlepool’s Public Space CCTV system provides significant operational and evidential benefit to
the Council, Emergency Services, Retail Premises, Licensed Premises, and to the public.

Conducting a Privacy Impact Assessment on surveillance camera systems (CCTV) (07.17) 9

4. Is it proportionate to the problem that it is designed to deal with? Explain why the level of privacy
interference is proportionate to the overall privacy impact.
Yes. The Public Space CCTV system enables 24/7 monitoring of areas at risk of crime and disorder.

The CCTV system assists, supports and complements the work of the Council, Emergency Services,
and the members of the Safer Hartlepool Partnership in reducing crime, disorder, substance misuse,
and re-offending, and in protecting public buildings and areas, and improving public safety and
confidence.

The CCTV system is operated within the relevant legislation and Codes of Practice.

5. Do any of these measures discriminate against any particular sections of the community?
Detail whether the proposed surveillance will have a potential discriminatory or disproportionate impact
on a section of the community. For example establishing a surveillance camera system in an area with a
high density of one particular religious or ethnic group.
No. The CCTV system is located around Hartlepool in vulnerable localities and areas which are
historically subject to, or at risk of persistent and often higher than average levels of crime and disorder.
The CCTV system is operated within the relevant legislation and Codes of Practice.

All CCTV operators have received specialist accredited training regarding their role, responsibilities and
legal duties, and are licensed by the Security Industry Authority for working as CCTV operators.

Conducting a Privacy Impact Assessment on surveillance camera systems (CCTV) (07.17) 10

PRIVACY IMPACT ASSESSMENT LEVEL TWO
The Level 2 privacy impact assessment template is designed to give organisations a simple and easy to
use document to record various placements and devices on their surveillance camera system and to
demonstrate the recognition and reduction of ‘risk’ to privacy impact across their network or system.

This document seeks to satisfy the privacy impact assessment in principle two of the Surveillance
Camera Code of Practice.

Principle 2 - The use of a surveillance camera system must take into account its effect on
individuals and their privacy, with regular reviews to ensure its use remains justified.

When looking at the obligation under the code a risk assessment methodology has been developed to
help organisations identify any privacy risks to individual or specific group of individuals (e.g. children,
vulnerable people), compliance risks, reputational risks to the organisation and non-compliance with the
Protection of Freedoms Act and/or the Data Protection Act.

A system that consists of static cameras in a residential housing block will generally present a lower risk
than a system that has multiple High Definition Pan Tilt and Zoom (PTZ) cameras. However, the privacy
impact assessment should help identify those cameras (irrespective of the type) that may be directed at
a more vulnerable area (e.g. a children’s play area) and therefore presenting a higher privacy risk. This
approach allows the organisation to document a generic approach to the intrusion into privacy, catalogue
your cameras by type and location, and finally identify any cameras that present specific privacy risks
and document the mitigation you have taken.

An example of a risk assessment guide is shown in Appendix One

When undertaking a privacy impact assessment, it is important to be able to confirm where the
organisation’s cameras are sited. The system asset it is considered to be good practice for all
organisations to maintain an asset register for all of their devices. This allows the system owner to record
each site and equipment installed therein categorised in a manner to lead into the level two process.

If any new site or installation sits outside of the pre-defined fields, then new categories can be added as
required

Overall step one and step two will cover the uses of devices of the system. However, it may not be
practicable to publically list or categorise each individual asset.

A register can be developed to capture the information required.

Conducting a Privacy Impact Assessment on surveillance camera systems (CCTV) (07.17) 11

Template – Level Two

Step 1 (definition of camera types utilised)

Cameras Specification: System operator owner should include below all camera types and system
capabilities (e.g. static, PTZ, panoramic, ANPR) and their likely application and expected use. This will
differ by organisation, but should be able to reflect a change in the cameras ability due to upgrade.

Please see example below:

ID Camera Makes and Amount Description Justification and expected use

types models used
1. Standard Confidential - Static images, no Public Space CCTV monitoring
Static movement or zoom by CCTV Control Room 24/7 hrs
function. Standard
definition images.
2. Standard Confidential - Pan, tilt and zoom Public Space CCTV monitoring
PTZ function. Standard by CCTV Control Room 24/7 hrs
definition images.
3. High-zoom Confidential - Pan, tilt and zoon Public Space CCTV monitoring
PTZ function. High by CCTV Control Room 24/7 hrs
Definition images.
4. HD static Confidential - Static images, no Public Space CCTV monitoring
movement or zoom by CCTV Control Room 24/7 hrs
function. High
definition images.
5. HD PTZ Confidential - Pan, tilt and zoom Public Space CCTV monitoring
function. High by CCTV Control Room 24/7 hrs
Definition images.
6. Covert Confidential - Mobile deployable Public Space CCTV monitoring.
cameras.
7. ANPR 0 0 n/a n/a
Cameras
8.
9.
10.
11.
12.

Step 2 (location assessment)

Location: Each system operator/owner should list and categorise the different areas covered by
surveillance on their system. This list should use the specifications above which ID (types) are used at
each specific location.

CAT Location Camera Amount Recording Monitoring Assessment of use of

type types used equipment (mitigations
or justifications)
A. Town centre Confidential 16 24 hrs for 31 24 hrs The location historically
days experiences persistent
higher than average
levels of crime and

Conducting a Privacy Impact Assessment on surveillance camera systems (CCTV) (07.17) 12

CAT Location Camera Amount Recording Monitoring Assessment of use of
type types used equipment (mitigations
or justifications)
disorder which continue
despite action by
agencies. The privacy
level expectation in a
Town Centre is very low.
The public is made
aware of the Council's
use of cameras by
appropriate signage.
B. Shopping Confidential 16 24 hrs for 31 24 hrs The location historically
Parades days experiences persistent
higher than average
levels of crime and
disorder which continue
despite action by
agencies. The privacy
level expectation at a
Shopping Parade is very
low. The public is made
aware of the Council's
use of cameras by
appropriate signage.
C. Industrial Confidential 17 24 hrs for 31 24 hrs The location historically
Estates days experiences persistent
higher than average
levels of crime and
disorder which continue
despite action by
agencies. The privacy
level expectation on an
Industrial Estate is very
low. The public is made
aware of the Council's
use of cameras by
appropriate signage.
D. Car Parks Confidential 7 24 hrs for 31 24 hrs The location historically
days experiences persistent
higher than average
levels of crime and
disorder which continue
despite action by
agencies. The privacy
level expectation in a
public Car Park is very
low. The public is made
aware of the Council's
use of cameras by
appropriate signage.
E. Open Space Confidential 6 24 hrs for 31 24 hrs The location historically
days experiences persistent
higher than average
levels of crime and
disorder which continue

Conducting a Privacy Impact Assessment on surveillance camera systems (CCTV) (07.17) 13

CAT Location Camera Amount Recording Monitoring Assessment of use of
type types used equipment (mitigations
or justifications)
despite action by
agencies. The privacy
level expectation in a
play area is high. The
public is made aware of
the Council's use of
cameras by appropriate
signage. CCTV
operators are subject to
extensive training and
oversight as detailed in
question 7 on page 6.
F. Residential Confidential 11 24 hrs for 31 24 hrs The location historically
Street days experiences persistent
higher than average
levels of crime and
disorder which continue
despite action by
agencies. The privacy
level expectation in a
residential area is
high/very high. The
public is made aware of
the Council's use of
cameras by appropriate
signage. CCTV
operators are subject to
extensive training and
oversight as detailed in
question 7 on page 6.
G. Council Confidential 43 24 hrs for 31 24 hrs The location historically
Building days experiences persistent
higher than average
levels of crime and
disorder which continue
despite action by
agencies. The privacy
level expectation in a
public area very low.
The public is made
aware of the Council's
use of cameras by
appropriate signage.
H.
I.
J.
K.
L.

Conducting a Privacy Impact Assessment on surveillance camera systems (CCTV) (07.17) 14

Step 3 (Cameras where additional mitigation required)

Asset register: It is considered to be good practice for all organisations to maintain an asset register for
all of their devices. This allows the system owner to record each site and equipment installed therein
categorised in a manner to lead into the level two process.

If any new site or installation sits outside of the pre-defined fields, then new categories can be added as
required

Overall step one and step two will cover the uses of devices of the system. However, it may not be
practicable to publically list or categorise each individual asset.

Please document here any additional mitigation taken on a camera or system to ensure that privacy is in
line with the ECHR requirements.

Camera Reviewed Camera Location Further mitigation/ comments (optional)

number type category
N/A N/A N/A N/A N/A.

Step 4 (Mitigation for specific cameras that have high privacy risks)

For the occasion where there is a very high impact an Authority may wish to conduct an extensive PIA of
specific installations and the site and have it fully documented.

PIA for specific installations

Camera number N/A

Camera location N/A

Privacy risk(s) Solution Outcome (Is the risk Justification (Is the impact after
removed, reduced or implementing each solution justified,
accepted) compliant and proportionate to the
aim of the camera?)
N/A N/A N/A N/A

Conducting a Privacy Impact Assessment on surveillance camera systems (CCTV) (07.17) 15

Privacy risk(s) Solution Outcome (Is the risk Justification (Is the impact after
removed, reduced or implementing each solution justified,
accepted) compliant and proportionate to the
aim of the camera?)

Agreed with: N/A

Signature N/A

Date N/A

Review date N/A

Conducting a Privacy Impact Assessment on surveillance camera systems (CCTV) (07.17) 16

APPENDIX ONE: PRIVACY RISK ASSESSMENT MATRIX
Scoring could be used to highlight the risk factor associated with each site if done utilising the risk matrix
example shown below.

Matrix Example:

Camera Types (low number low impact – High number, High Impact

Location

Types

A (low
impact)

Z (high
impact)

Conducting a Privacy Impact Assessment on surveillance camera systems (CCTV) (07.17) 17

APPENDIX TWO: STEPS INVOLVED IN CONDUCTING A
PRIVACY IMPACT ASSESSMENT

Understand and establish the pressing need through problem analysis. Consider all possible solutions
e.g. lighting, target environmental, hardening etc. If a surveillance camera system identified as most
appropriate, then conduct a privacy impact assessment.

Identify the legal basis for the surveillance camera system.

Identify the personal information the system will gather and consider how it will be used.

Identify the level of privacy intrusion and privacy risks through consultation with stakeholders
and the public.

Weigh up the necessity and proportionality of your system against any privacy intrusion.

Find ways to reduce the privacy intrusion to proportionate levels or decide not to proceed.

Review your system regularly (at least annually) to ensure that it remains necessary and privacy
intrusion is justified and proportionate.

Conducting a Privacy Impact Assessment on surveillance camera systems (CCTV) (07.17) 18