OFFICIAL - PUBLIC
OFFICIAL - PUBLIC
Police Service of Northern Ireland
Body Worn Video (BWV)
Privacy Impact Assessment
Published
Version 1.1
August 2016
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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
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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
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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.
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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.
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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:
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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.
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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
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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]
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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
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DPA
Principle
Number
Principle BWV Control Processes and procedures adopted
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.
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DPA
Principle
Number
Principle BWV Control Processes and procedures adopted
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.
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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.
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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.
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Figure 1.0: High-level business flow
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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
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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.
Non-compliance with the
DPA;
Non-compliance with
PSNI’s Information
Security Policies;
Non-compliance with
human rights legislation.
Risk of non-compliance
with Data Protection
Legislation;
Risk of litigation /
challenge from staff /
officers.
Individuals’ audio
may be recorded by
device without them
being fully aware.
Privacy of
individuals may be
compromised.
Non-compliance with the
DPA;
Non-compliance with
human rights legislation.
Risk of non-compliance
with Data Protection
Legislation;
BWV technology
allows information to
Information
pertaining to
Non-compliance with the Risk of non-compliance
with Data Protection
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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
human rights legislation.
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.
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.
Fairness of video
evidence taking.
Risk that measures
taken against
individuals as a
result of collecting
video information
might be seen as
intrusive.
Non-compliance with the
DPA;
Non-compliance with
human rights legislation.
Risk of noncompliance
with Data Protection
Legislation;
Risk of litigation /
challenge from members
of the public.
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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
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Risk Solution(s) Result Evaluation
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
All staff will receive
training before being
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.
All staff will receive
training before being
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.
All staff will receive
training before being
given access to
equipment;
PSNI will review
processes as usage
Reduced Reduction in
likelihood of risk
occurring makes
approach
proportionate for
the policing areas
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Risk Solution(s) Result Evaluation
continues. under
consideration.
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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
Training & Technical controls
as recorded within project
documentation.
BWV Project Board
Risk of non-compliance with
internal PSNI guidance.
Training & Technical controls
as recorded within project
documentation.
BWV Project Board
Risk that information is shared
inappropriately with partner
agencies
Training & Technical controls
as recorded within project
documentation.
BWV Project Board
Risk to vulnerable people
through inappropriate usage of
equipment.
Training & Technical controls
as recorded within project
documentation.
BWV Project Board
Risk that video evidence taking
is not seen as fair.
Training & Technical controls
as recorded within project
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
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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
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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.
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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.
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Approximate
Date
Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed
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.
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Approximate
Date
Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed
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.
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Approximate
Date
Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed
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.
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Approximate
Date
Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed
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
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Approximate
Date
Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed
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
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Approximate
Date
Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed
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
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Approximate
Date
Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed
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
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Approximate
Date
Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed
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
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Approximate
Date
Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed
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
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Approximate
Date
Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed
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.
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Approximate
Date
Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed
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?
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Approximate
Date
Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed
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
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Approximate
Date
Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed
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
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Approximate
Date
Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed
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
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Approximate
Date
Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed
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
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Approximate
Date
Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed
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
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Approximate
Date
Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed
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
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Approximate
Date
Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed
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,
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Approximate
Date
Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed
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
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Approximate
Date
Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed
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
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Approximate
Date
Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed
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
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Approximate
Date
Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed
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
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Approximate
Date
Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed
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
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Approximate
Date
Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed
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
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Date
Consultee Group Summary of comments / issues raised Remedial Actions proposed Date completed
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
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Date
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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.
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