Template For Automatic Number Plate Recognition (Anpr) Infrastructure Development Privacy Impact Assessment Page 3
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9Part 1
Screening Questions
1
Will the project involve the collection of new information about
individuals?
Vehicle Registration Marks (VRM) will be obtained from locations not previously
monitored by ANPR and therefore new information will be obtained from those
locations.
2
Will the project compel individuals to provide information about
themselves?
The collection of VRM is automatic at the locations and therefore when an
individual drives a vehicle at the new locations they could be considered as
compelled to provide information. The Surveillance Camera Code describes
overt surveillance in public places in pursuit of a legitimate aim and that meets a
pressing need, as surveillance by consent. Such consent on the part of the
community must be informed consent and not assumed by a system operator.
Subject therefore to compliance with DPA and appropriate consideration of
privacy, individuals can be considered to consent to the provision of information
at the locations as opposed to being compelled to provide the information.
3
Will information about individuals be disclosed to organisations or people
who have not previously had routine access to the information?
Whilst information from new locations will be disclosed it will only be disclosed
to those organisations that currently have access to ANPR data.
4
Are you using information about individuals for a purpose it is not
currently used for, or in a way it is not currently used?
The new ANPR infrastructure will provide ANPR data for the same purposes as
for the data already obtained from ANPR systems. The developments will not
alter the way in which it is used.
5
Does the project involve you using new technology that might be
perceived as being privacy intrusive? For biometrics or facial recognition.
The project does not involve the use of new technology that might be perceived
as privacy intrusive.
6
Will the project result in you making decisions or taking action against
individuals in ways that can have a significant impact on them?
The purpose of the proposed development of infrastructure is in order to detect,
deter, and disrupt criminality and therefore impact significantly on those
involved in such activity.
7
Is the information about individuals of a kind particularly likely to raise
privacy concerns or expectations? For example, health records, criminal
records or other information that people would consider to be private.
ANPR data is personal data since it can be combined with other information by
an LEA to provide data relating to an individual. ANPR data does not however
constitute private information since it is collected overtly in circumstances where
there is no reasonable expectation of privacy. It therefore does not give rise to
significant privacy concerns or expectations.
8
Will the project require you to contact individuals in ways that they may
find intrusive?
There is no requirement to contact individuals.
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