RECORDING DEVICES -
PH AND TAXI DRIVERS: WHAT YOU NEED TO KNOW ABOUT DATA PROTECTION AND IN-CAR CAMERAS
Article by Dave Lawrie Director NPHTA
info@nphta.co.uk
Data protection law sets out what should be done to make sure everyone’s personal information is used properly and fairly. It is based on seven principles that outline how you should use (process) people’s personal information. It also gives people rights about their personal information.
As a taxi or private hire driver you’ll probably have personal information about your customers and clients, such as names, addresses and contact details. But many licensed drivers also use inward facing (in- car) cameras in their vehicles.
If you use a camera in your vehicle, this article is aimed at you, as any footage of people captured by that camera is likely to be personal information and anything you do with that information, including saving, viewing, or sharing it, is ‘processing’. So, data protection law applies. You will need to know who is responsible (the controller) for how that information is processed. When using cameras that capture personal information including passengers’ faces or voices, it’s important to protect people’s privacy and follow data protection law. A Data Protection Impact Assessment (DPIA) helps you check the risks to personal information.
You need to do a DPIA if there’s likely to be a high risk to people. For example, if you’re planning to process sensitive data such as information about children or vulnerable adults, or passengers’ conversations, you’ll likely need to do a DPIA first. Here is a handy DPIA template to guide you through the process and ensure you cover all necessary steps to protect personal data and comply with data protection laws:
https://shorturl.at/4aAYo
To help you understand data protection law, the NPHTA and the Information Commissioner’s Office (ICO) have put together this article, including a helpful checklist. It isn’t intended to be a comprehensive list or
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include everything you will ever need to know about the law, but it is designed as a quick and easy checklist for private hire and taxi drivers who are considering using in-car cameras.
1. Are you a controller?
Data protection law applies to all businesses or organisations of any type that use personal data. We call these people (data) controllers, which means they are legally responsible for the use of, collection, storage, access, control, of personal information (data).
NPHTA says: “In your sector, where installation in your vehicle is a mandatory requirement of licensing, the local authority may be the controller. Where it remains a voluntary requirement, you must identify who the controller is. It may still be the local authority if it has a restricted access policy, it may be yourself or a nominated person or organisation.”
2. Be clear, fair and comply with the law (lawfulness, fairness, transparency principle)
You need to comply with the law, including data protection rules. You’ll need to make sure that passengers know they’re being filmed, so have signs up to make sure passengers know they’re entering an area that is covered by cameras that will be processing (recording) their personal data.
Don’t record your passengers’ conversations unless you really need to. Where there is audio, it must be off by default and should only be activated where justifiable, such as when there is a threat to you or your passengers.
NPHTA says: “Have the camera signage at each passenger entry point - close to the door handles is good, as this means that passengers are more likely to see it as they enter the vehicle.
“If you need to activate audio monitoring it should only be by the use of a visible activation switch.”
APRIL 2025 PHTM
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