CCTV: WELSH GOVERNMENT NATIONAL CCTV STANDARD
Constantly watching UK wide developments
At Safe Systems CCTV Ltd, we reached out to the Welsh Government to suggest working together to update and make some improvements to a CCTV policy included in its guidance for Welsh local authorities.
Welsh Government desire to get it right
The response and call to action was extremely well received and acted on, which led to several meetings and email exchanges to ensure the draft policy was clear, before sharing with several working groups, including all Welsh local authorities for further consideration and comments.
Wider consultation
Next we went out to wider consultation with other system suppliers, there was only one major supplier that submitted comments, which included detailed paragraphs to explain what the term: “removable hard drive carrier” meant, so we added the word “caddy” to the description to show that we had seen it, and understood their point.
Online sessions – Deeper internal debates: Q&A
Once we had what we considered to be the final draft, then came time to delve into various other aspects, such as:
1. Should it be nationally mandatory – No
2. Who is the Data Controller – Where mandatory, the council
3. What does being a data controller mean – Direct access to data
4. Do we need to have a separate data controller – No
5. Should there be an override switch? – Yes, ICO regulations were discussed, but we also discussed the ongoing challenge to this requirement, and what that “might” mean
6. Should audio be constant for school contracts – No
Once all this was completed, we opened up a wider consultation, before finally adopting the new approach in September 2024.
60 Putting together the jigsaw puzzle
As you can see, this was no quick fix topic, in fact it was a very detailed and very technical debate. Consid- eration had to be placed on the requirements set by drivers, local authorities, passengers, data protection and UKGDPR, police and courts, education authorities and everyone else; putting all that together, satisfying every requirement, developing a criteria which complied, whilst also checking that there are systems available, or indeed adaptable to meet them all.
What was wrong with the original?
The original version was out of date and had various technical errors, legislative errors and some contradictions, such as:
l One part suggested the system remain operational for two hours without power from ignition, whilst another section suggested 30 minutes.
l The criteria was written to state “must be
compatible with windows 8”, which has now been replaced by windows 11, but that was a contradiction in terms, since the system had to be encrypted, which meant that the data could not be windows compatible at all.
l Time to download entire data to take no longer than 30 minutes, this would actually be an offence, since the only data which may be accessed, is that which relates to an alleged offence “legitimate interest”.
There was more, which was why we had to go through every line, and make sure that every “I” was dotted, and every “T” crossed.
I have to say, it was smooth, proficient and incredibly detailed; in fact, it was an honour and a privilege to have worked with such a professional official and very down to earth and approachable team.
We obviously discussed other matters too.
This CCTV Criteria has also been adopted by various English local authorities, and it is hoped that this will become the UK-wide standard to make sure it is clear, simple and achievable.
The CCTV policy is available here:
https://www.gov.wales/taxi-and-private-hire-vehicles- cctv-policy-template-local-authorities
MARCH 2025 PHTM
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