Here are a few tips and observations on how to handle Subject Access Requests which include CCTV footage. As a leading provider of redaction services in Ireland Datascan Redaction have learned how to avoid some common pitfalls in this area. These are based on our experience of handling video footage over the last five years.
Redaction – sometimes referred to as pixelation, is the removal of personally identifiable data from video footage, CCTV Footage, stills and photographs, or documentation. The first thing to establish is what you need to redact. This could be the faces of staff members, public, patients or children. That is the obvious one, but you also need to take other identifying factors into consideration such as uniform emblems, house numbers, physical locations, car vehicle registrations and more.
The Data Processing Agreement
Our advice is to have your own DPA ready for consideration. If the CCTV clip is being submitted on behalf of a firm that has a legal department, they will want to consider the DPA too, this can delay the process even further. Work will not commence until the DPA is in place.
Delivery Of Footage for Processing
Download the piece of footage to USB/DVD and have it encrypted as a preference. You will need to know what CCTV system the footage is from (e.g. Dahua, Avigilon etc.) as the technician may need the player program from the CCTV recorder to view the footage. Datascan Redaction can offer a secure encrypted link for you to upload footage to us.
We set realistic expectations for our client – poor quality footage will give a poor-quality result. Full HD footage will need to be zoomed in on the zone of any incidents and this can be very revealing. Another piece of advice is to properly identify the Data Subject – use a specification for the project. Just because it is obvious to you who the subject is, doesn’t mean it will be clear to a technician. Remember the time on CCTV camera footage may not be accurate and may not match the time of day.
Security of Data
Redaction is time consuming and can be expensive. It is important to pre-qualify only the length of footage absolutely required for the SAR. Incidents such as slips, trips, falls in a commercial premises are normally less than 3 minutes of video footage. If the footage is part of a SAR requesting lengthy footage, try to take the opportunity to qualify down the length of footage needed.
Datascan Redaction are the first company in Ireland to obtain ISO27001 certification for CCTV Redaction Services. Why is this important? It is an internationally recognised certification that gives the reassurance to you that your data is secure at all stages of the process.