OFFICIAL - PUBLIC...The screening questions and responses in the previous section indicate that the...

OFFICIAL - PUBLIC

OFFICIAL - PUBLIC

Police Service of Northern Ireland

Body Worn Video (BWV)

Privacy Impact Assessment

Published

Version 1.1

August 2016

OFFICIAL - PUBLIC PSNI – Privacy Impact Assessment - Body Worn Video (BWV)

OFFICIAL - PUBLIC 2 | P a g e

Document Classification

This document (“Privacy Impact Assessment – Body Worn Video”) has been prepared by PSNI

and is classified as Official (Public).

Document Version

Date Version Description

April 2016 0.1 – 0.3 Internal Drafts

11/05/2015 0.4 Updated following PSNI Business review

12/05/2016 0.5 Additional amendments

13/05/2016 0.6 Additional stakeholders

25/05/2016 0.7 Updated following PSNI senior business review

01/07/2016 0.8 Updated following comments from ICO

07/07/2016 0.9 Following review by business owners

1.0 Published

11/08/2016 1.1 Amendment following final ICO review



Contents

1. EXECUTIVE SUMMARY ............................................................................................................................. 4

2. SCREENING QUESTIONS ........................................................................................................................... 5

3. THE NEED FOR A PRIVACY IMPACT ASSESSMENT .................................................................................... 6

PURPOSE OF A PRIVACY IMPACT ASSESSMENT ............................................................................................................... 6

4. LEGISLATIVE CONSIDERATIONS RELATING TO USE OF BWV ..................................................................... 7

LEGISLATION UNDERPINNING ITS USE ........................................................................................................................... 8

COMMON LAW ....................................................................................................................................................... 8

EUROPEAN CONVENTION OF HUMAN RIGHTS ACT 1998 ................................................................................................ 8

DATA PROTECTION ACT (DPA) 1998 ....................................................................................................................... 10

FREEDOM OF INFORMATION ACT.............................................................................................................................. 12

5. INFORMATION FLOWS FOR BODY WORN VIDEO ................................................................................... 14

BUSINESS PROCESS FLOW ....................................................................................................................................... 14

6. CONSULTATION REQUIREMENTS ........................................................................................................... 16

NI STAKEHOLDERS ................................................................................................................................................. 16

NATIONAL STAKEHOLDERS INFORMED AND CONSULTED ................................................................................................. 17

7. IDENTIFIED PRIVACY AND RELATED RISKS ............................................................................................. 17

8. IDENTIFY PRIVACY SOLUTIONS .............................................................................................................. 19

9. SIGN OFF AND RECORD PIA OUTCOMES ................................................................................................ 22

10. INTEGRATE THE PIA OUTCOMES BACK INTO PROJECT PLAN .............................................................. 22

11. APPENDICES ...................................................................................................................................... 24



1. Executive Summary

In common with other UK police services, and in line with recommendations from a number of

sources including the policing college, senior police officers’ associations and the Home Office, PSNI

has initiated a project to implement the use of body worn video (BWV) devices across the service in

line with national guidelines. Various studies have shown benefits can be achieved through the

prudent use of this technology within modern policing. PSNI’s key objective is to enhance the

accuracy and reliability of evidence gathered when a police officer attends the scene of a crime or

incident. The project must enable the capture of visual and audio evidence at a wide range of high

volume front line policing incidents including:

Stop & Search;

Public order offences;

Domestic violence and domestic related crime; and

Motoring offences.

On completion of the project, BWV will be deployed in the following units:

Local Policing Team;

Tactical Support Group;

Roads Policing Unit;

Dog Section;

District Support Team;

Armed Response Vehicle*; and

Neighbourhood Policing Team.

* Note that the use of BWV for armed response teams is subject to different procedures. However,

in all cases, the use of BWV equipment must be incident specific, proportionate, legitimate,

necessary and justifiable.

Recognising that this will have an impact upon the privacy of individuals ranging from victims,

witnesses and suspects through to officers and the general public, PSNI has initiated a privacy impact

assessment. This PIA document has been created to examine the risks and document the mitigation

processes, procedures and controls that will ensure a proportionate and pragmatic use of this

technology for the greater good of the Northern Ireland community. The approach taken has been

to consider the impact upon individual’s privacy using the Data Protection Act (DPA) principles as a

framework against which the controls may be mapped. PSNI is the Data Controller for this data as

defined by the DPA.

PSNI proposes to consult with a large number of representative bodies in respect of the use of this

technology. This process has already commenced and a log of progress is included as an appendix to

this document.

This document will be updated at each further stage in the project; i.e. when additional

consultations are completed and also when additional districts go live. The intention is to regularly

review the use of BWV to ensure that its application meets best practice now and going forward.

PSNI – Privacy Impact Assessment - Body Worn Video (BWV)

5 | P a g e

2. Screening Questions

1 Will the project involve the collection of new

information about individuals?

Yes – the project will result in video images and

audio of individuals being recorded.

2 Will the project compel individuals to provide

information about themselves?

Yes – the recording of video and audio is instigated

by the officer and is dependent upon his / her

judgement.

3 Will information about individuals be disclosed

to organisations or people who have not

previously had routine access to the

information?

Yes

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?

Yes – with the exception of CCTV security systems

and public order videoing, PSNI do not routinely

record video of individuals during domestic and

other incidents.

5 Does the project involve you using new

technology that might be perceived as being

privacy intrusive?

Yes – the use of body worn video resulting in the

recording of video images and audio of individuals

is generally perceived to be potentially intrusive to

an individual or individuals.

6 Will the project result in you making decisions

or taking actions against individuals in ways

that can have a significant impact on them?

Yes – research into the use of body worn video has

shown that the inclusion of video evidence may

prove to be compelling in court cases leading to a

higher level of prosecution. It could therefore be

argued that the project will result in decisions being

taken which have a significant impact on different

individuals (witness, victims and/or suspects)

directly connected with the incident or case. It

should be noted that there will be no such impact

on third party individuals who are not directly

related to the case.

7 Is the information about individuals of a kind

particularly likely to raise privacy concerns or

expectations?

Yes – The use of images and audio generally raises

greater privacy concerns amongst individuals. This

may be particularly true in respect of by-standers /

members of the public not directly involved in a

particular incident but who are within the camera’s

field of view.

8 Will the project require you to contact

individuals in ways that they might find

intrusive?

No – there is no additional requirement to contact

individuals as a result of this project.



3. The need for a Privacy Impact Assessment

The Police Service of Northern Ireland (PSNI) established a pilot project to test body worn video (BWV) in

2014. Body worn video refers to lightweight video camera systems which are attached to an officer’s

uniform and which can be switched on and off by the officer. The devices purchased are to a UK Policing

specification with:

150 Degree Horizontal Field of View;

720 p HD Video quality;

8 hours continuous recording capacity or 48 hours standby;

Evidence quality images and processes.

BWV has the potential to provide significant benefit to normal policing through the collection of additional

evidence. BWV can prove to be a very cost effective aid to policing especially in sensitive areas such as stop

& search, public order offences, motoring offences and domestic violence. However, the solution also has

the potential to create privacy issues for members of the public as well as police officers and staff.

Individuals going about their normal everyday activities will potentially be “captured” by devices worn on

police uniforms and it is important that this is factored into the use of the devices.

The screening questions and responses in the previous section indicate that the Body Worn Video project is

likely to raise issues of privacy. This privacy impact assessment (PIA) has been written to explore these issues

and in particular to explain:

1. The rationale for PSNI introducing and using this technology;

2. The legislation underpinning its use;

3. The likely operational scenarios into which the devices will be deployed and used;

4. The key privacy issues and risks and how these will be mitigated; and

5. How PSNI will monitor the use of the equipment and revisit Privacy issues.

This documentation should be read in conjunction with operational guides provided by the College of

Policing and the National Chief Officers’ forum.

Purpose of a Privacy Impact Assessment

Every project or set of new processes / procedures that involves exchanging personal information has the

potential to impact upon an individual’s privacy. It is important therefore, that any organisation seeking to

make changes demonstrates that they have considered the impact (if any) upon the general public and, if

necessary, have introduced suitable controls, checks and balances to reduce any unanticipated effects.

The Information Commissioner’s Office Conducting Privacy Impact Assessments code of Practice describes

privacy in the following way:



Privacy, in its broadest sense, is about the right of an individual to be left alone. It can take two main forms,

and these can be subject to different types of intrusion:

Physical privacy – the ability of a person to maintain their own physical space or solitude. Intrusion can come

in the form of unwelcome searches of a person’s home or personal possessions, bodily searches or other

interfaces, acts of surveillance and the taking of biometric information;

Informational privacy – the ability of a person to control, edit, manage and delete information about

themselves and to decide how and to what extent such information is communicated to others. Intrusion

can come in the form of collection of excessive personal information, disclosure of personal information

without consent and misuse of information. It can include the collection of information through the

surveillance or monitoring of how people act in public or private spaces and the monitoring of

communications whether by post, phone or online and extends to monitoring of senders and recipients as

well as the content of messages.

The privacy impact assessment is a process, which helps organisations to anticipate and address the likely

privacy impacts of projects, to minimise the likelihood of problems subsequently occurring.

4. Legislative considerations relating to use of BWV

The PSNI BWV Project has defined the scope of the project as follows:

PSNI’s key objective is to enhance the accuracy and reliability of evidence gathered when a police officer

attends the scene of a crime or incident. The project must enable the capture of visual and audio evidence at

a wide range of high volume front line policing incidents including:

Stop & Search;

Public order offences;

Domestic violence and domestic related crime; and

Motoring offences.

BWV will be deployed in the following units:

Local Policing Team;

Tactical Support Group;

Roads Policing Unit;

Dog Section;

District Support Team;

Armed Response Vehicle*; and

Neighbourhood Policing Team.

* Note that the use of BWV for armed response teams is subject to different procedures. However, in all

cases, the use of BWV equipment must be incident specific, proportionate, legitimate, necessary and

justifiable.



PSNI will have a total of 2,100 camera and charging units and these will be used by up to approximately 3200

officers following training. Equipment will be allocated to and shared by members of each unit. However, an

electronic system will ensure that a camera has been associated with an individual officer. Cameras will be

stored in their docking stations when not in use to enable charging.

In all cases, the rationale for using the equipment must be clearly outlined prior to use.

Legislation underpinning its use

The use by PSNI of BWV must be shown to be proportionate, legitimate, necessary and justifiable. In

addition, the Service must be able to demonstrate that the use of this equipment addresses a “pressing

social need”. This is especially in respect of its application within the confines of the Articles enshrined by

the European Convention of Human Rights within the Human Rights Act 1998 which came into force in

October 2000.

Common Law

Legality under Common Law. The police are able to rely on the fact that the use of BWV is deemed lawful

under Common Law1. Police Officers are also held to be “citizens in uniform” although granted additional

statutory powers in order to execute their duties. In addition, police officers generally do not require special

statutory powers to undertake any activity that the public could lawfully undertake. The taking of

photographs including videos and associated sound recordings is deemed lawful and Common Law does not

prevent this activity in a public place.2

European Convention of Human Rights Act 1998

For the purposes of the European Convention of Human Rights (ECHR)and the Human Rights Act 1998, it has

been determined that police officers have sufficient powers in common law to justify the use of BWV as

above (Wood V Commissioner of Police for the Metropolis [2009]). However, use of BWV is viewed as “an

interference” and must always be justifiable. Therefore, any actions by the police must have a legitimate aim

and the use of video equipment must be proportionate to achieving this. Under this legislation a number of

articles, protect the rights of citizens. Some of these Articles are absolute whereas others are “qualified” and

any interference with these is limited.

Interference with qualified rights is permissible only if:

There is a clear legal basis for interference with the qualified right that people can find out and

understand;

The Action/ Interference seeks to achieve a legitimate aim. Legitimate aims are set out in each article

containing a qualified right and vary from article to article. For example, they include National Security,

the prevention of disorder or crime or public safety. Any interference with one of the rights contained in

article 8-11 must fall under one of the permitted aims set out in the relevant article; and

The action is necessary in a democratic society. This means that the action or interference must be in

response to a pressing social need and should be assessed by demonstrating evidence of a level of

severity or immediacy / unpredictability, and alternatives should have been reviewed.

1 BWV - Privacy Impact Assessment – Hampshire Constabulary

2 Lord Collins in Wood v Commissioner of Police for the Metropolis 2009



The use of BWV must comply with all the article of the ECHR, and there are two particular Articles that are

critical and most likely to be challenged:

Article 8 of the ECHR is the right to respect for private and family life, home and correspondence; and

Article 6 of the ECHR provides for the right to a fair trial.

Under the legislation, Article 8 is a qualified right and, police forces are required to consider this article when

dealing with recorded images, whether they are made in public or private areas. This assessment looks to

address the issues raised by this Article and introduces safeguards, associated with how PSNI deploys this

equipment in both private and public arenas. Throughout, the principle objective is ensuring that any

interference with the rights of parties can only be justified if it is:

Necessary;

In pursuit of a legitimate aim; and

In accordance with the law.

Legal advice indicates that the use of BWV would be in accordance of the law. All images taken via a BWV

device have the potential for use in court proceedings whether they provide information that is beneficial to

the prosecution or defence. The information will be safeguarded by an audit trail in the same way as other

evidence that is retained for court. It should be emphasised that BWV does enable police to collect valuable

evidence for use in criminal prosecutions, ensures the police act with integrity and transparency and

potentially provides objective evidence of controversial events. It offers protection for both citizens and the

police.

The justification is likely to be closely scrutinised by the court and it is critical that recordings are not

retained where there is no clear evidence of an offence, unless some other good reason exists for their

retention.

Recordings of conversations between members of the public must always be considered private, even in

public spaces. In a similar way, recordings made in public places are only public to those there at the time

and must therefore be considered as potentially private. 3 Users of BWV must consider this article when

recording and must mot record beyond what is necessary for policing purposes. PSNI has established

process and procedure which provide clear guidelines where BWV is planned to be used in private places or

where a person or persons being recorded would reasonably have a strong expectation of privacy. These

guidelines include:

Intimate searches – BWV will not, under any circumstances, be used for recording intimate searches or in

any other circumstances where persons are in a state of undress.

Legal privilege – users must respect legal privilege and must not record material that is, or is likely to be,

subject to such protections.

Expectation of Privacy – individuals will almost certainly have a strong expectation of privacy in places not

generally not open to the public, such as a private residence especially at a time of day when people are

likely to be in bed. Clear justification of the need to use BWV will be required. Furthermore, circumstances

3 R v Brentwood Borough Council ex parte Peck [2003]



may dictate an expectation of privacy even when an incident has occurred in a public area, such as where

someone may be the subject of an accident in the street.

Likely to cause offence – care should be exercised in using BWV where it may cause serious offence, for

example during a religious ceremony.

BWV should not be used for formal investigative interviews. The use of BWV for the interview of suspects is

not permitted as it would be in contravention of PACE Code C.

Data Protection Act (DPA) 1998

The Data Protection Act 1998 is legislation that regulates the processing of personal data including sensitive

personal data, whether processed on a computer, CCTV, stills camera or any other media. Any recorded

image and audit recording from any device, which includes body worn video, that can identify a particular

person or learning about their activities, is described as personal data and is covered by the DPA and in

particular within the principles contained within.

Principle 1 of the DPA (fair and lawful processing) requires that the data subject is informed of:

a. The identity of the data controller;

b. The purpose or purposes for which the material is intended to be processed; and

c. Any further information that is necessary for processing to be fair.

PSNI has the responsibility for controlling this information and is known as the data controller for

information captured within Northern Ireland for policing purposes. If required, a police officer using a BWV

device must be prepared to explain how the capture and processing of the data is compliant with the legal

obligations imposed under this Act. Table 1.0 below maps the controls and rationale for BWV’s use against

each of the DPA principles.

Table 1.0: DPA Principles mapping

DPA

Principle

Number

Principle BWV Control Processes and procedures adopted

1 Personal data shall be processed fairly and lawfully

and, in particular, shall not be processed unless –

(a) at least one of the conditions in Schedule 2 is

met; and

(b) in the case of sensitive personal data, at least

one of the conditions in Schedule 3 is also

met.

PSNI is defined as the Data Controller for this

information.

Lawful and fair processing of BWV data is

considered to be achievable as conditions in both

schedule 2 and 3 of the Data Protection Act can

be met:

Processing of personal data associated with BWV

meets the conditions outlined in paras 3 and 4 of



DPA

Principle

Number


Schedule 2 of the DPA. These are:

“Legal obligation of the Data Controller” to

investigate potential crime; and

“processing necessary for the administration of

justice”.

Furthermore, as the data is sensitive personal

data, schedule 3 conditions relating to the

administration of justice and the protection of

the vital rights of the data subject or others (in

this case the victim) are considered to apply.

Criminal justice also gain some exemptions under

the ACT where the personal data is being

processed to enable the prosecution of offenders

which is a clear objective of the BWV project.

2 Personal data shall be obtained only for one or more

specified and lawful purposes, and shall not be further

processed in any manner incompatible with that

purpose or those purposes.

BWV footage is obtained for the lawful purpose

of crime investigation and/or prevention. As

detailed above, this is defined within Schedules 2

and 3 of the DPA.

3 Personal data shall be adequate, relevant and not

excessive in relation to the purpose or purposes for

which they are processed.

Officers are required to use their judgement as

to when they start and stop the video camera.

The camera should be stopped immediately the

incident has finished. The information recorded

must meet the proportionate use principle and

must include sufficient information to allow the

context of the situation to be understood.

4 Personal data shall be accurate and, where necessary,

kept up to date.

The video and audio footage taken is a snapshot

in time, relating to a particular incident and is not

updatable. As such it is deemed to be an

accurate and up to date record of the incident at

the time it was recorded.

5 Personal data processed for any purpose or purposes

shall not be kept for longer than is necessary for that

Video footage which is not used as evidence is

deleted after 31 days in line with guidelines.



DPA

Principle

Number


purpose or those purposes. Video material which is to be used as evidence

will be held in line with MOPI guidelines going

forward when PSNI has fully adopted MOPI.

6 Personal data shall be processed in accordance with

the rights of data subjects under this Act.

The rights of individuals has been considered

within section 4 above.

7 Appropriate technical and organisational measures

shall be taken against unauthorised or unlawful

processing of personal data and against accidental

loss or destruction of, or damage to, personal data.

Technical controls in place include:

User authentication;

Audit trails;

Data encryption on devices.

Organisational measures include the provision of

training for all users prior to deployment and

access to on-line guidance.

8 Personal data shall not be transferred to a country or

territory outside the European Economic Area unless

that country or territory ensures an adequate level of

protection for the rights and freedoms of data

subjects in relation to the processing of personal data.

Information is not stored outside of the UK. All

data stored is subject to strict internal security

guidelines and only accessible by authorised

staff.

Freedom of Information Act

The Freedom of Information Act 2000 grants a general right of access to all types of recorded information

held by public authorities, which will include digital images such as those recorded by body worn video. The

Act does however, provide some specific exemptions to the general requirement to disclose information.

Part 2 of the Protection of Freedoms Act 2012 deals with the regulation of CCTV and other surveillance

camera technology and introduces the code of practice for surveillance camera systems. Section 29(6) of the

Act provides that this code covers “any other systems for recording or viewing visual images for surveillance

purposes”. PSNI adheres to this code as its content will be relevant when a court is considering the use of

body worn video.

The Home Office code of practice on the management of police information (MoPI) consist of a guidance and

a code of practice. It directs how the police service will handle any data that comes into its possession. Data,

which includes information from a BWV device, may only be retained for a “police purpose” and this covers

all situations where a police officer exercises a police power, where they would have ordinarily made a

record in their pocket notebook, or there is a strong and reasonable presumption towards the collection /

capture of evidence.



There may be occasions where a police officer wishes to record an encounter to evidence their own actions;

there must be a legitimate reason to this decision and the recording cannot be used for the sole purpose of

aiding the identification of the an individual, in that this has been held to be unlawful as per Wood V

Commissioner of Police for the Metropolis 2009.

The decision to record in these circumstances needs to be taken in line with the principles of data

management and record retention and the provisos contained within this assessment. Officers should be

prepared to account for their decision-making in such instances. The guidance further states that policing

purpose includes:

a. Protecting life and property;

b. Preserving Order;

c. Preventing the commission of offences;

d. Bringing offenders to justice; and

e. Any duty or responsibility of the police arising from common law or statute.

These five purposes provide the legal basis for collecting, recording, evaluating, sharing and retaining police

information. The guidance provides a framework on how any data captured by the police can be used and

processed. In addition, it details the process to be used by the police to initially retain information, to review

this and when to ultimately dispose of data after requisite timescales and circumstances.

PSNI are moving as a corporate body to comply with MoPI and BWV information shall be subject to this

guidance. Procedures are in place to manage subject access requests in respect of video and audio captured

using BWV equipment. Requests will be managed by PSNI’s FOI team and will require requesters to provide

date, time, and location of the recording together with a photograph of themselves to aid identification.


14 | P a g e

5. Information Flows for Body Worn Video

Business Process Flow

The diagram in Figure 1.0 shows the high-level business process flow governing the use of the Body Worn

Video device. The purpose of this diagram is to provide the reader with an understanding of the information

which is being captured, who it is potentially shared with, how it is used and how it is stored. In addition, it

provides an overview of the retention and destruction of this data.

The retention period for this data will depend upon the outcome of the investigation. If the investigation

officer makes a determination that there is a case to answer the footage will be retained as evidence until

after the court case has completed.

On commencement of an assigned activity an officer may be required to check out a BWV device. This

device will be authenticated to the officer and will have no data stored on it. During normal patrolling the

device will be inert. If an incident or suspected incident has occurred, the officer will then make a decision

to use the device based upon the proportionate, legal and reasonable use of the device. The date, time and

location should form part of the initial [verbal] warning that the device is now in use and is recording both

audio and video. It is preferable that this warning is included at the start of the recording where possible or

practical. The recording is likely to continue for a short period after the incident has concluded to ensure

that subsequent viewers are aware that the incident has concluded.

Once the officer has captured video images he/ she will return to the station and dock the device. The data

will be stored onto a secure back office storage area. Once the information has been successfully stored, the

application will issue an erase command to the device which will wipe the device ready for its next use.

Using the back office video management software the footage may be stored as evidential. Additionally, a

partial extract may be produced. This extract will normally be a subset of the video shot, focussed on the

offence whilst ensuring sufficient contextual information is displayed. The back office video management

software also enables the officer to pixilate any bystanders appearing in the evidential video who are not

associated with the case. The evidential copy is stored on a media storage facility with access controls

restricting access to the officer(s) involved in the case based upon the initial authentication at device

allocation and the reviewing officer etc. The source video images cannot be altered.

If the information recorded is not saved as evidential and will not form part of a subsequent prosecution, the

information will be automatically deleted after 31 days. If the information has been saved as evidential and

therefore relevant to a possible prosecution then the data will be held online until a period after the court

case and then will be archived.


15 | P a g e

Figure 1.0: High-level business flow


16 | P a g e

6. Consultation Requirements

PSNI recognises that there are a number of stakeholders with an interest in how the body

worn devices will be deployed and used within policing in Northern Ireland. A number of

consultations have already been undertaken and the intention is to build upon this good

work. Given the structure in place between the police and the community through the

policing and community safety partnerships, it is intended to use this channel to inform

stakeholders and to obtain feedback on the Privacy Impact Assessment district by district.

In addition, a number of organisations which have an interest in the work of the police, be

they government agencies or NGOs have been identified and will be contacted to solicit

their views on the use of BWV. The organisations consulted by PSNI in respect of body worn

video are listed below.

NI Stakeholders

Policing and Community Safety Partnerships

Public Prosecution Service (PPSNI)

Northern Ireland Courts and Tribunal Service

Law Society

Police Ombudsman for Northern Ireland

Children’s Law Centre

NSPCC

Forensic Science NI

NI Commissioner for Children and Young People

Men’s Advisory Project

Victim Support Northern Ireland

Northern Ireland Fire and Rescue Service

Health and Social Care Northern Ireland

Department of Justice Northern Ireland

Northern Ireland Ambulance service

St John Ambulance – Northern Ireland

HM Coastguard volunteers

Age UK Northern Ireland staff and members

Red Cross Northern Ireland staff and volunteers

RSPCA - Northern Ireland

Street Pastors Northern Ireland

Northern Ireland Chamber of Commerce

Visit Northern Ireland (tourism)

Federation of Small Businesses Northern Ireland

Harbour Commissioners

Harbour Police

Airport Police

MOD



National Crime Agency (NCA)

HM Customs and Excise

Home Office Immigration

Women’s Aid

National stakeholders informed and consulted

College of Policing

Information Commissioner's Office (ICO)

Home Office Body-Worn Video National User Group

7. Identified privacy and related risks

Table 4.1 summarises the possible privacy issues identified through the use of body worn

video devices and considers the risk to individuals.

Table 4.1: Possible Privacy Issues

Privacy Issue Risk to

Individuals

Compliance Risk Associated

Organisation /

Corporate Risk

Camera Field of View

may include

individuals (members

of the public, officers

staff, etc.) known as

bystanders not

directly involved in

the incident.

Video of individuals

may be stored

within PSNI

systems;

Security risk that

information is not

properly secured.

Non-compliance with the

DPA;

Non-compliance with

PSNI’s Information

Security Policies;

Non-compliance with

human rights legislation.

Risk of noncompliance

with Data Protection

Legislation;

Risk of litigation /

challenge from members

of the public.

Cameras, which are

not turned off within

police estate may

record colleagues

inadvertently.

Privacy and

security of

individual officers

may be

compromised.


DPA;

Non-compliance with


Security Policies;

Non-compliance with


Risk of non-compliance


Legislation;


challenge from staff /

officers.

Individuals’ audio

may be recorded by

device without them

being fully aware.

Privacy of

individuals may be

compromised.


DPA;

Non-compliance with


Risk of non-compliance


Legislation;

BWV technology

allows information to

Information

pertaining to

Non-compliance with the Risk of non-compliance




Privacy Issue Risk to

Individuals

Compliance Risk Associated

Organisation /

Corporate Risk

be shared with

multiple agencies.

individuals may be

shared between

agencies without

the individual’s

knowledge.

DPA;

Non-compliance with


Legislation.

Use of BWV in

circumstances

involving vulnerable

people.

Vulnerable people

may be concerned

about the use of

cameras and/or

potential for

misuse of cameras.


DPA;

Non-compliance with


Security Policies;

Non-compliance with




Legislation;



of the public.

Fairness of video

evidence taking.

Risk that measures

taken against

individuals as a

result of collecting

video information

might be seen as

intrusive.


DPA;

Non-compliance with




Legislation;



of the public.


19 | P a g e

8. Identify Privacy Solutions

This section considers the risks identified in section 4 above and applies mitigating solutions

to each risk. It then evaluates whether the mitigations are sufficient to provide assurance

that the solution is proportionate.

Table 5.1: Privacy Solutions identified and assessed

Risk Solution(s) Result Evaluation

Risk of Non-

compliance with

Data Protection

Legislation.

PSNI’s process and

procedures will be

documented and

mapped/ tested against

data protection

guidelines. Audit

processes will be

implemented to test

adequacy of controls in

place.

Reduced

Reduction in

likelihood of risk

occurring makes

approach

proportionate for

the policing areas

under

consideration.

Risk of non-

compliance with

Human Rights

legislation

Back Office Video

Management software

has capability to pixilate

individuals’ features

thereby making them

unidentifiable. PSNI

guidance will clearly

direct officers and staff

to use this facility when

creating an image for

use in court.

Guidance will also

reinforce the need to

turn the camera off

when inside police

buildings and to make a

public announcement

when turning the device

on.

Reduced

Reduction in

likelihood of risk

occurring makes

approach

proportionate for

the policing areas

under

consideration.

Risk of non-

compliance with

internal PSNI

All staff will receive

training before being

given access to

Reduced

Reduction in

likelihood of risk

occurring makes




guidance. equipment;

Accountability - audit

trail of equipment and

its use tied back to

individual officers;

Process will be subject

to independent internal

audit as per annual

audit plan.

approach

proportionate for

the policing areas

under

consideration.

Risk that information

is shared

inappropriately with

partner agencies



given access to

equipment;

Information sharing

between agencies has a

number of technical and

protocol controls in

place to prevent

unauthorised sharing.

Reduced

Reduction in

likelihood of risk

occurring makes

approach

proportionate for

the policing areas

under

consideration.

Risk to vulnerable

people through

inappropriate usage

of equipment.



given access to

equipment;

Accountability - audit

trail of equipment and

its use tied back to

individual officers;

Process will be subject

to independent internal

audit as per annual

audit plan.

Reduced Reduction in

likelihood of risk

occurring makes

approach

proportionate for

the policing areas

under

consideration.

Risk that video

evidence taking is

not seen as fair.



given access to

equipment;

PSNI will review

processes as usage

Reduced Reduction in

likelihood of risk

occurring makes

approach

proportionate for

the policing areas




continues. under

consideration.


22 | P a g e

9. Sign off and record PIA Outcomes

Risk Approved Solution Approved By

Risk of Non-compliance with

Data Protection Legislation.

Training & Technical controls

as recorded within project

documentation.

BWV Project Board

Risk of non-compliance with

Human Rights legislation



documentation.

BWV Project Board

Risk of non-compliance with

internal PSNI guidance.



documentation.

BWV Project Board

Risk that information is shared

inappropriately with partner

agencies



documentation.

BWV Project Board

Risk to vulnerable people

through inappropriate usage of

equipment.



documentation.

BWV Project Board

Risk that video evidence taking

is not seen as fair.



documentation.

BWV Project Board

10. Integrate the PIA Outcomes back into Project plan

Action to be taken Date for completion of

actions

Responsibility for action

Training of staff to be

completed prior to

releasing equipment.

TBC Project team

Technical controls in

respect of access control

and secure erasure to be

tested.

TBC Project Team

Stakeholder briefings and

consultations to be

completed – on a rolling

As per project plan Project Team



basis prior to roll-out in

particular districts

Testing of FOI / SARs

process to ensure that

information can be

retrieved in a timely

manner.

As per project plan Project Team


24 | P a g e

11. Appendices

Consultation Log

This section will record the consultations held and summarise any issues which were raised and how

they were addressed. The log will be updated on a regular basis.


25 | P a g e

Consultation Log

Approximate

Date

Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed

23/5/16

Derry City & Strabane

PCSP

PCSP updated re introduction of new

cameras to replace the proof of concept

cameras in the District.

27/9/16 Belfast East PCSP Members raised the following queries in relation to the presentation:

a) Question: How long is footage stored for?

Answer: The PSNI will adhere to national guidelines which currently allow non-evidentiary data to be kept for 31days before being wiped/deleted – this will be done automatically by the systems software. It footage is marked as evidential; it will be retained under Management of Police Information (MoPI) regulations. b) Question: Can solicitors or complainants access the footage? Answer: As part of a police interview the footage can be accessed and played alongside solicitors. It is hoped, and evidence would suggest, that this will lead to quicker justice outcomes.



Approximate

Date


c) Question: How is data transferred back to the station, and is the camera tamper proof? Answer: When an Officer requests a Body Worn Camera from the system, the most suitable device (with full charge etc.) will flash indicating that it should be used. Following use of the camera, it is returned to the docking station at which point the recordings are uploaded to the system and the camera is wiped. The uploaded recordings are then marked as evidentiary or otherwise. The camera itself is tamper proof and encryption ensures that if lost or stolen, the data would not be of use as it must be returned to the docking station for information to be obtained. d) Question: Will every Officer be issued with a camera? Answer: The PSNI has purchased 2,200 units at a cost of approximately £750,000, under the estimated budget. This allows every on-duty Officer to have access to a camera over a 24 hour period. Efficient use of the system means that there is no need for a personal issue to each Officer.



Approximate

Date


e) Question: When will the cameras be used, and what happens if they are lost? Answer: Cameras should be used to compliment the observations of Officers. The device will normally be off and an Officer will be required to make a professional judgement / assessment about when to activate it based upon guidance and training. Where possible, a warning that video and audio is now being recorded will be issued (this may not be possible in a public order situation). The device will be turned off once the incident has concluded. A light will also flash during filming. The equipment itself is very robust and waterproof. If a device was to be lost, the footage could not be accessed by the public, and would only be lost to the PSNI. f) Question: Can a member of the public ask for the camera to be switched on? Answer: Yes, however it would be hoped that if a situation required it, the Officer would already have activated the camera. If the camera is not used where appropriate, questions would be asked of Officers.



Approximate

Date


g) Question: Can a witness ask for the camera to be switched off? Answer: There may be occasions where the camera may need to be turned off however this would be at the discretion of the Officer who may feel the need to decline the request. Statements from witnesses would most likely be obtained in a different setting than those anticipated in the use of body worn camera which is designed to help in evidence gathering during domestic violence incidents, stop and search and public disorder. h) Question: Are Officers content with the deployment of Body Worn Video? Answer: The cameras have been welcomed as they are useful in gathering evidence and supporting victims in cases. While not the reason for deploying the cameras, they can also assist when allegations made against Officers where little evidence often exists to support or refute the claims made. The footage will also be helpful to the Police Ombudsman, allowing investigators to see incidents from the perspective of Officers.



Approximate

Date


i) Question: Are other agencies or domestic violence groups receiving similar presentations from the PSNI? Answer: This is being done, and further

presentations can be set up by

arrangement.

28/9/16 Belfast West PCSP A Member asked if information recorded on the camera could be used to assist with complaints received by the PSNI at a later date. Members advised of the procedures that would be undertaken by PSNI Officers when uploading the information from the camera and how the data captured is retained automatically for a period of 31 days. She further commented that if the PSNI Officer marked footage as evidence, the evidence is retained indefinitely by the PSNI, until any investigation is concluded. A Member asked if there had been age limit restrictions for recording someone with the body worn camera. Members informed that there had been no age restrictions regarding who can be recorded using body worn cameras. She further commented that PSNI Officers



Approximate

Date


would adhere to the Home Office Guidelines regarding the use of the body worn cameras and minors. A Member asked if a PSNI Officer had the option of deleting data captured by the camera. Members advised that an Officer cannot delete the data from the camera at the time of recording and that the software system would automatically delete data after 31 days, unless it is marked as evidential. The Chair asked if the body worn camera is switched on automatically or is it turned on at the discretion of the PSNI Officer. Members advised that the PSNI Officer switches on the camera.

10/10/16 Belfast PCSP Members raised the following queries in relation to the presentation: a) Question: Will footage assist with malicious allegations against Officers, and have the cameras been sufficiently tested against fire/damage? Answer: Footage will assist with complaints



Approximate

Date


against Offices, and the PSNI have been working with the Police Ombudsman regarding the introduction and implementation of Body Worn Video. The equipment itself is very robust and has been tested under various conditions. The contract in place also has provisions should the equipment be found to have major faults. b) Question: Has the equipment been purchased or hired? Answer: A pool of cameras has been bought to ensure all Officers have access to a camera however each Officer will not be issued their own. c) Question: Will Officers ask victims for consent to turn the camera on, and what would happen if consent was withdrawn at a later stage? Answer: Officers do not require consent to use the cameras however they would wish to have support from those involved and would explain the need for its use. There may be occasions where the Officer would agree with the request not to film however a statement would be taken and other



Approximate

Date


evidence collection would continue. Once the footage is recorded it is the property of the PSNI and so no further consent would be needed to proceed with prosecution. Superintendent Steen advised that such issues had not arisen as yet. d) Question: Are copies of the footage made available to solicitors, and if so, how are these sent and stored? Answer: Viewing and sharing digital evidence will be governed as part of a disclosure package which is not yet in place. Once operating, a secure email link will be provided. The PSNI is currently looking at the use of encrypted DVDs with 1 provided to the PPS and 1 for the defence team, all of which will be governed by Data Protection Legislation. Once passed on, the DVDs become the responsibility of the agencies which hold them. e) Question: By whom and at what stage is footage edited, and can defence teams access unedited footage? Answer: The PSNI will take direction from the PPS. The PSNI will disclose the length and nature of the footage and make any



Approximate

Date


edits requested and all footage will be made available to the defence if requested. f) Question: How long is footage stored for and what considerations are given to filming young people and vulnerable adults? Answer: The PSNI will adhere to national guidelines which currently allow non-evidentiary data to be kept for 31days before being wiped/deleted – this will be done automatically by the systems software. If footage is marked as evidential; it will be retained under Management of Police Information (MoPI) regulations. Officers have not been told that children or vulnerable adults should not be recorded and so, as with all recording, professional judgement will be required when activating cameras. g) Question: Could footage be used in post-conviction work with offenders in order to challenge behaviours? Answer: Many inadvertent uses for Body Worn Video have been identified, including as a developmental tool for Officers, and



Approximate

Date


so this could be another useful outcome. h) Question: What direction will be issued to Officers regarding the use of the cameras, and has consideration been given to the impact on community confidence should the cameras not be utilised appropriately? Answer: Guidance has been issued to Officers who are aware that cameras should be utilised during domestic violence incidents, stop and search, and public disorder. If not used, Officers will be asked to explain their actions. A clear rationale for why cameras are switched on and off is needed. Cameras may also be useful when gathering evidence at road traffic accidents, during searches or at murder scenes. The use of cameras will be monitored and changes made if common difficulties are emerging. i) Question: What statistics are available regarding the impact of cameras in escalating or de-escalating incidents? Answer: The randomised control tests carried out to date do not have these



Approximate

Date


details however they would suggest that assaults on Officers increased by a small percentage, however this could not be linked to the use of cameras. viii. In response to a query about the recovery of footage once it has been deleted, agreed to contact the Technical Team to seek clarity on the issue. BWV footage that has not been marked as

evidential within the video manager

system will be automatically deleted after

the expiry of 31 days, the footage cannot

be recovered once deleted from with this

system. PSNI have agreed with the

Information Commissioner’s Office that

footage which is not denoted as evidential,

within the 31 days from ingestion, is not

admissible as evidence in a prosecution.

Note - Evidential material will be saved for

a period of time in accordance with

Management of Police Information (MOPI)

guidelines.



Approximate

Date


26/10/16 Belfast North PCSP Members raised the following queries in relation to the presentation: a) Question: What are the consequences for PSNI Officers who do not switch the cameras on? Answer: Members advised that this would be regarded as a non-compliant issue. She further commented that if the PSNI Officer had access to the tool that would assist them to gather evidence, they should utilise it. However it was highlighted the importance of PSNI Officers using their discretion when using the body worn cameras. b) Question: Does the PSNI Officer have to inform the member of the public that the body worn camera is turned on? Answer: Members advised that the PSNI Officer has to inform the member of the public that the body worn camera is in use and is recording. c) Question: Is the identity of the person being recorded protected?



Approximate

Date


Answer: Members advised that a risk assessment approach was always taken and the PSNI Officer would never do anything to jeopardise a person’s identity. d) Question: Does the Police Ombudsman have access to the footage captured by the boy worn cameras? Answer: Yes. e) Question: Can a member of the public request for the body worn camera to be turned on?

Answer: Yes, but the scenario may

dictate whether the body worn camera is

activated.

29/11/16 Belfast South PCSP Members raised the following queries in relation to the presentation: Would there be a sanction if an officer

failed to record?

Line management issue in the first

instance.

Can an officer delete footage?

Footage cannot be deleted by an Officer. If

the footage is not saved as evidence it will



Approximate

Date


automatically be deleted after 31 days.

What is the cost for Belfast?

Have no cost for Belfast specifically,

approximately £1.5M for the Service.

30/11/16 Armagh, Banbridge &

Craigavon PCSP

Is there an age limit for who can be

recorded?

These cameras could be used with individuals under the age of 18. How many cameras will there be for each

District?

Approximately 2,200 cameras had been purchased. Every officer would have access to a camera. When would it not be appropriate for use?

As soon as officers received training they would be expected to carry a camera when on duty. These would support people and would also support crime. Custody suites had made provision for large screens so footage could be provided during interviews. This may encourage individuals to enter an early guilty plea and



Approximate

Date


save officers’ time. The recordings were high quality HD colour. Sometimes the audio recording was more important than the video. How will it benefit domestic violence

investigations?

The camera could also be used to assist with domestic violence enquiries. There were a number of occasions where the victim had withdrawn from prosecution. In a Court of Appeal this could be a way of taking forward prosecutions. How long is the information kept for?

The recording system would automatically wipe after 31 days however if the recording could assist with prosecution it may be kept for longer. Is there a backup after 31 days?

If footage is not saved as evidence, it will

automatically delete after 31 days with no

way of retrieving it.

24/1/17 Newry, Mourne & Down If an officer decides to switch the



Approximate

Date


PCSP camera either on or off, can this decision be overridden by a Sergeant?

Officers would be asked to use their professional judgement depending on the scenario as to whether to switch the camera on or off. There was no override facility however if the camera was not used in an incident, questions would be asked of that officer.

Does a red light come onto the camera to alert members of the public that they were being filmed?

There were two flashing red lights to indicate that the camera was recording and a green light on top for officers to be able to ensure the camera was working.

If there were 3 members in a police patrol, do the officers have a camera each?

If there were 3 officers in a patrol, there was sufficient technology for



Approximate

Date


all officers to take a camera and for them to be deployed.

Was there any way in which the technology could be misused?

There would be very little chance for the technology to be misused. Officers must book camera out and dock it back in. If officers make a judgement that footage was evidential it does not go out of the system, if it was decided the evidence was not evidential it was automated after 31 days. If the technology had been misused, officers run a high risk of that being identified within the 31 day period.

Was there any evidence in relation to the savings to the justice agencies or police generated through the technology?

An outline business case was presented to the Department for Justice to buy and deploy the technology. The bid was for £3.4m and to date it has cost £1m. The



Approximate

Date


savings would be in terms of speeding up the processing of perpetrators as the camera offers visual and audio evidence of a crime having taken place and this can be played back immediately as a suspect was being interviewed.

Did the technology record quality sound and vision?

There was both good audio and visual capability on the cameras.

Could the recordings be watched live, was there Wi-Fi capability?

There are no Wi-Fi capabilities at present due to the risk of data loss and whether the data would be compromised.

If recordings were edited, does the recording then become irrelevant as evidence against potential perpetrators?

Officers can edit the recordings to dub out sounds or people’s faces if



Approximate

Date


for example a stranger-on-stranger assault occurred, it would not be good to remind either party of the appearance of the other. There were multiple layers of securing built into the technology.

24/1/17 Fermanagh & Omagh

PCSP

Who can view the footage?

The Officer recording the footage,

supervising an incident or investigating an

incident, with a lawful Policing purpose.

What warnings are given?

Officer will when practicable to do so

announce that a video and audio recording

is being made. The camera displays two

red lights on the front of the camera when

recording.

How does it help with domestic violence?

Potentially providing evidence from a

witness first account.

What is the subject access process?

Subject access request for BWV is the same

as any other request for personal data,



Approximate

Date


details on the PSNI website.

What is the policy for sharing?

Evidence will be shared with Criminal

Justice partners, PPS, Courts in relation to

prosecution cases.

9/3/17 Causeway Coast &

Glens PCSP

Does use of the camera challenge human rights or privacy?

How effective are these camera’s in low light situations?

How long is video data held for? Is that checked against the Data Protection Act?

Does the presence of a camera have the chance to aggravate a situation?

Following an incident of domestic violence, does every member of the PSNI response team who visits the premises in the future, wear a camera?

29/3/17 Antrim &

Newtownabbey PCSP

Will a verbal warning be given every time

they are used?

Given at every practicable opportunity. In

some incidents there may not be a chance



Approximate

Date


for the officer to issue a warning right

away, but thereafter as soon as is

practicable.

Will cameras only to be used by uniformed

officers?

At this stage it would be uniformed

officers, however could be used by any

officer who has completed the required

training.

Have the cameras been used in support of

evidence?

In an incident of domestic violence, where

the victim did not wish to give evidence,

officers video evidence was submitted

instead which secured a conviction.

What could the reasons be for instances of

assaults on police having gone up during

the pilot?

Further research is required in this area

before assessments could be made.

To whom must the officer justify the use of



Approximate

Date


the video camera to?

The officer who has captured the footage

will review the images and if they believe

there is evidential material, the images will

be downloaded. If not, the images will be

deleted automatically after 31 days.

Has the person being videoed the right to

sue for breach of privacy and is it

legitimate to take footage of persons inside

a licensed premises?

The camera is there to protect both

parties, if the officer is asked to turn the

camera off, the officer will use their own

judgement and discretion in each case. Not

aware of any cases to date where officers

have been challenged with a breach of

privacy. Officers may need to investigate

breaches of licensing legislation and it may

therefore be reasonable for officers to take

footage to record evidence.

16/5/17 Lisburn & Castlereagh Will BWV be disclosed as evidence in a



Approximate

Date


PCSP prosecution case?

BWV evidence will be subject to the same

disclosure considerations as other

evidence.

6/6/17 Ards & North Down

PCSP

Would a full original of evidential footage

always be kept if an edited version is

made? Yes, master copy of footage saved

when evidence is retained.

How will BWV benefit domestic violence

investigation if incident had concluded on

arrival of Police? Ans. Witness first account

being captured. If the injured party

withdrew the statement this would be

evidence and could be used for court

proceedings.

Will footage be available to PONI if a

complaint is made? Ans. Yes

What is the data retention policy?

Ans. The data retention period of 31 days

complied with Home Office regulations and

was automatically deleted after this time



Approximate

Date


unless it was kept for evidence purposes.

Will the cameras reduce the amount of

paperwork police officers were required to

complete, or have any other type of cost or

time saving? Ans. unlikely to decrease the

amount of paperwork but there had been

an increase in the number of guilty pleas

and fewer cases were contested in other

areas where the project had been

launched.

How long evidence being used for court

cases could be retained for? Ans. explained

that it could be kept for up to one year or

until the trial ended.

Could the cameras be used instead of

handheld cameras? Ans. The body cams

were not replacements for handheld

cameras and would be used in different

types of situations.

14/6/17 Mid Ulster PCSP Where will the information be stored? An Officer will dock the camera on return to the police station where evidence can be viewed. The information is centrally



Approximate

Date


stored in Belfast. Footage is deleted if saved as evidence within 31 days.

28/6/17 Mid & East Antrim PCSP Which Officers will be using the cameras?

All front line Officers will have use of BWV

in Local Policing Team, Neighbourhood

Policing Team, Tactical Support Group

including Dog Section, District Support

Team, Roads Policing.

19/05/2017

Public Prosecution

Service (PPSNI)

19/05/2017

Northern Ireland Courts

and Tribunal Service

19/05/2017

Law Society

19/05/2017

Police Ombudsman for

Northern Ireland

19/05/2017 Children’s Law Centre Welcomes the consultation but requests



Approximate

Date


clarity in relation to Section 75 of the

Northern Ireland Act 1998, GDPR, ECHR,

and suggested inclusion of outline of child

protection measures when recording with

BWV.

19/05/2017

Northern Ireland

Commissioner for

Children and Young

People

19/05/2017

Include Youth

Issue raised on the decision to start and

finish recording resting with the Officer.

Workshop with group of young people to be

arranged to discuss use of BWV.

22/1/18

19/05/2017

Article 16 meetings led

by DoJ

19/05/2017

NSPCC

19/05/2017 Forensic Science NI



Approximate

Date


19/05/2017

Men’s Advisory Project

19/05/2017

Victim Support

Northern Ireland

19/05/2017

Northern Ireland Fire

and Rescue Service

No adverse comment to make on your

proposed direction of travel in this regard.

19/05/2017

Health and Social Care

Northern Ireland

SE Trust thank you for giving the Trust the

opportunity to review the PSNI PIA in

respect of body worn video. The Trust is

content with the control measures in place

by the PSNI as outlined in the PIA.

Separate query on need for use of RIPA.

Use of BWV will be overt, and any collateral

intrusion can be redacted before sharing with

other CJO partners.

19/05/2017 Department of Justice



Approximate

Date


Northern Ireland

19/05/2017

Northern Ireland

Ambulance service

19/05/2017

St John Ambulance –

Northern Ireland

19/05/2017

HM Coastguard

volunteers

HM Coastguard HQ and all are very

supportive of the initiative and have no

concerns. We would only ask that if

possible you notify HM Coastguard in

advance of a go live date so that we may

make our staff aware prior to any potential

collaborative working.

HM Coastguard informed of go live dates for

BWV.

19/05/2017

Age UK Northern

Ireland staff and

members



Approximate

Date


19/05/2017

Red Cross Northern

Ireland staff and

volunteers

19/05/2017

RSPCA - Northern

Ireland

19/05/2017

Street Pastors Northern

Ireland

As Belfast Street Pastors, we often work in

conjunction with the PSNI and we value

the growing relationship. BSP is keen to

see any developments which help to

ensure that people, police officers, as well

as BSPs on the streets at night are kept

safe and protected from inappropriate

behaviour. For this reason, we are pleased

to see the introduction of BWV for Police,

and do not object to the use of these

devices, provided they are used in

accordance with guidelines issued and set

out in the attached PIA, i.e. incident

specific, proportionate, legitimate,

necessary and justifiable. We understand

that if an officer sees the need to use the



Approximate

Date


BWV in any incident involving Street

Pastors, it will be on the basis that it is

necessary, e.g. in pursuit of a legitimate

aim, and in accordance with the law. In

such a case, we see its use as an aid to

collect additional evidence that it may

provide for investigation. We are

committed to the protection and well-

being of the general public, and would

encourage the PSNI to ensure that the

identity and actions of those not directly

involved in any incident being recorded are

protected from inappropriate or

unreasonable use.

19/05/2017

Northern Ireland

Chamber of Commerce

19/05/2017

Visit Northern Ireland

(tourism)

19/05/2017 Federation of Small

Businesses Northern



Approximate

Date


Ireland

19/05/2017

Harbour Commissioners

19/05/2017

Harbour Police

19/05/2017

Airport Police

19/05/2017

MOD

19/05/2017

National Crime Agency

(NCA)

The NCA supports PSNI’s project in relation

to body worn video and acknowledges the

privacy impact assessment. We note that

the use of BWV equipment must be

incident specific, proportionate, legitimate,

necessary and justifiable, and request that

where necessary and appropriate PSNI

advises when BWV equipment is utilised in

any joint NCA/PSNI operation, so the NCA



Approximate

Date


officers can be appropriately briefed.

19/05/2017

HM Customs and Excise

19/05/2017

Home Office

Immigration

19/05/2017

Women’s Aid

We are encouraged that the PSNI intends

to roll out Body Worn Video as a tool to

assist with policing of a range of issues,

including domestic violence and abuse.

We would submit that there is an

established presumption of value in using

BWV in the course of attending and

policing domestic violence incidents.

It should be made clear that the

aftermath of a domestic incident is

important to record for the context

of the situation to be understood,

not just the physical act itself

reassuring victims that the use of

BWV doesn’t meant that they will

be forced to go to court

Meeting to be arranged. See 30/6/17



Approximate

Date


concern that the CJS may still be

pushing the responsibility for

domestic violence onto victims

BWV footage can only be held for

30 days

concerns over disclosure of BWV

evidence to perpetrators of

domestic violence

re perpetrators who self-represent

and post the BWV on-line or share

via email to embarrass or frighten

the victim

Point out the value of BWV in police

training and development – this may be a

useful dual purpose. Given the tight

budgetary constraints faced by PSNI, BWV

could be a valuable tool in helping police to

continuously develop professionally, by

reviewing footage to provide practical

examples of good practice.

19/05/2017

NI Coroner



Approximate

Date


19/05/2017

State Pathologist

department

19/05/2017

Probation Board

19/05/2017

Equality Commission NI

19/05/2017

Human Rights

Commission NI

19/05/2017

Trading Standards

19/05/2017

Health and Safety

executive

19/05/2017 HMIC



Approximate

Date


19/05/2017

Prisons NI

19/05/2017

OLCJ

19/05/2017

Parades Commission

19/05/2017

College of Policing

19/05/2017

Information

Commissioner's Office

(ICO)

19/05/2017

Home Office Body-Worn

Video National User

Group



Approximate

Date


19/05/2017

Surveillance

Commissioner

30/6/17 Women’s Aid Possibility of self-representing defendants

being supplied with copy of BWV footage.

PPS have since confirmed that the footage

would not be served on any unrepresented

defendants. The physical exhibit would be

marked ‘serve by inspection’ and, therefore, the

defendant would need to attend with the

Investigating Officer and watch the footage at

the police station.

26/7/17

23/11/17 Include Youth Decision to turn camera on/off resting with

the officer seen as possibly negative.

Could BWV lead to young people being

unnecessarily criminalised?

Proposal to arrange workshop with a group of

young people.

22/1/18 Include Youth workshop Potential for selective use of BWV with

encounters with young people. Sensitivity

raised re use of BWV in home environment

including care home environment.

Further discussion at Youth forum around use

of BWV with young people.



Approximate

Date


OFFICIAL - PUBLIC...The screening questions and responses in the previous section indicate that the...

Documents

Transcript of OFFICIAL - PUBLIC...The screening questions and responses in the previous section indicate that the...