Body Worn Video (BWV)
We're committed to protecting your privacy when you use our services. We have a data protection officer who makes sure we respect your rights and follow the law.
If you have any concerns or questions about how we look after your personal information, please contact us at[email protected].
Background
BWV is an overt method implemented by Luton Council to promote:
- the safety of the councils staff
- public reassurance
- capture evidence
- modify behaviour
- prevent harm
- deter people from committing a crime and/or engaging in anti-social behaviour
An awareness that a camera is recording can improve the conduct on both sides of an encounter. The footage recorded will provide unquestionable video and audio evidence of interactions between council officers and members of the public to ensure people are treated with dignity, respect and in a professional manner.
All recordings will be incident specific and the cameras will not be used indiscriminately to record all interactions. The cameras will only be switched on when an incident occurs or is suspected to occur.
All staff equipped with BWV cameras will receive full training. The training includes the practical use of equipment, best practice, when to commence and cease recording and the legal implications of using the equipment.
Council staff will inform individuals where possible that a device has been activated and is recording video and audio. Additionally, clear signage is displayed to notify that video and audio recording may take place.
BWV is used by a number of teams within the council. This includes but is not limited to:
- customer services
- neighbourhood enforcement
- investigations hub
- parking enforcement
- housing operations
- revenues and benefits (Council Tax)
- licensing
- environmental health
- dog wardens and pest control
The council is committed to compliance with the Information Commissioner’s Office’s data protection code of practice for surveillance cameras and personal data, the Home Office’s surveillance camera code of practice and the Code of Practice for Surveillance Cameras Systems operated by Luton Council.
Please be aware that we may need to make changes to our Privacy Notices, so please check our website for updates from time to time.
We process personal data to include images, videos and audio recordings to the extent that the data is visible in the images, videos or audio recorded by the BWV cameras.
Where footage includes evidence of an offence, it may be combined with other personal data about you including:
Personal data
- Name
- Date of birth
- Address
- Email address
- Phone number
- Vehicle Registration Numbers
- Other personal data deemed necessary and proportionate
Special category data
- personal data revealing racial or ethnic origin;
- personal data revealing political opinions;
- personal data revealing religious or philosophical beliefs;
- personal data revealing trade union membership;
- data concerning health;
- data concerning a person’s sex life; and
- data concerning a person’s sexual orientation
Personal data
UK GDPR Article 6(1)(c) - processing is necessary for the compliance with a legal obligation to which the controller is subject or;
UK GDPR Article 6(1)(e) and DPA 2018, section 8(c) - processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
Special Category data
UK GDPR Article 9(2)(g) and DPA 2018, Schedule 1, paragraph 6(1) & (2)(a) - processing is necessary for reasons of substantial public interest
Relevant legislation
This list is not exhaustive and devices will be used by a range of council officers under various powers whilst undertaking their duties. For example:
- Anti-social behaviour, Crime and Policing Act 2014
- Traffic Management Act 2004
- Environmental Protection Act 1990
- Licensing Act 2003
- Housing Act 2004
BWV footage may be shared with:
- other teams and services within Luton Council where law permits, or it is necessary to do so
- insurance agencies
- police
- Crown Prosecution Service
- legal representatives
- courts/tribunals
- other government departments and agencies specifically involved in public regulatory duties
- housing associations and landlords
- Environment Agency
- other law enforcement agencies
- other prosecution agencies
- third parties where it is lawful to do so
- Where evidence is held for the prevention and detection of crime and disorder and/or;
- Where footage is to be used in judicial proceedings, both criminal and civil
Any automated decision making or profiling
None
The majority of personal information is stored on systems in the UK. But there are some occasions where your information may leave the UK either in order to get to another organisation or if it’s stored in a system outside of the EU.
We have additional protections on your information if it leaves the UK ranging from secure ways of transferring data to ensuring we have a robust contract in place with any third party who may transfer it out of the EU.
If we need to send your information to an ‘unsafe’ location we’ll always seek advice from the Information Commissioner first.
The data will be kept in accordance with our retention schedule.
You have the right to ask us to amend or delete your data as well transfer or limit its use.
Each request will be considered individually. Where we are required to keep your data by law we may be unable to action your request. In all circumstances we will explain our decision making in writing to you.
Please see our main privacy statement using the green button below if you want more information on how:
- we keep your data safe
- to request a change to the records we hold
- to make a complaint