Fillable Self-Assessment-Tool-for-ANPR Self assessment tool

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Self assessment tool for Automatic
Number Plate Recognition
How well does your organisation comply with the 12 guiding
principles of the surveillance camera code of practice?
Complete this easy to use self assessment tool to find out if you do.
Using this tool
This self assessment tool will help you and your organisation identify if you’re complying with the
principles in the code. It should be completed in conjunction with the surveillance camera code of
practice (https://www.gov.uk/government/publications/surveillance-camera-code-of-practice). The tool
will help you show how well you comply with each principle. It is possible to be largely compliant with
some principles and to fall short against others. As a result you will note that at the end of the questions
against each principle there is a space to include an action plan. This is to enable you to put actions in
place over the next year to improve your compliance to that principle. These boxes can also be used to
make a note of what evidence you could produce if required to show your compliance to that principle.
Use of ANPR by Law Enforcement Agencies (LEA), which include police forces, is subject to National
ANPR Standards for Policing (NASP). NASP includes standards that support the principles of the code
and compliance with NASP is a good indication of compliance with the code. Police forces and other
LEA should consider this tool as part of any review of compliance with NASP and publish the result to
aid transparency and accountability. Some parts of NASP may be relevant to other users of ANPR and
are available at www.npcc.police.uk/anpr.
The tool contains a combination of open and closed questions. For the open questions there is a limit
on how much you can write, so please feel free to include any additional notes as an annex to the
document – there are additional blank pages at the end of the tool.
We do not want you to send the self assessment response to us. However, in the interest of
transparency we encourage you to publish the self assessment on your website.
The self assessment is for you to satisfy yourself and those that you surveille that you meet the principles
and identify any additional work to show compliance.
We would like you to let us know that you have completed this document as this will enable us to
understand the level of uptake. Also please let us know if you will be interested in working towards
certification against the surveillance camera code of practice in the near future or just be added to our
mailing list.
PLEASE COMPLETE ALL QUESTIONS
Please forward any feedback to scc@sccommissioner.gsi.gov.uk
Principle 1
Use of a surveillance camera system must always be for a specified purpose which is in pursuit of a
legitimate aim and necessary to meet an identified pressing need.
Standards for ANPR infrastructure development and use are included within NASP Part 2 Section 7.
Compliance with NASP is indicative of compliance with Principle 1.
1. Have you translated principle 1 into clear objectives to meet your pressing need?
Yes No
If so what are they?
2. Have you considered the requirement of the end user?
Yes No
3. Is the system being used for any other purpose other than those specified?
Yes No
If so please explain
4. Have you identified any areas where further action is required to more fully
conform with the requirements of Principle 1?
Action plan
Yes No
✔
✔
✔
✔
Support for Counter Terrorism due to the number of Military personnel living in Blandford and nearby Military camp.
Support and protection to the town's local community in the summer months when an increase in visitors to the area
contributes to a rise in crime.
Protection against the growing number of vehicles entering the town linked to Drugs.
Protection of local economy and shopkeepers against shop theft linked to traveling criminality.
To assist in identifying vehicles used by Drink and Drug drivers, to protect the local community.
Although it could be used if required to assist the Council with details of the types of vehicles entering the town if
required to assist with traffic management issues.
Principle 2
The use of a surveillance camera system must take into account its effect on individuals and their
privacy, with regular reviews to ensure its use remains justified.
Standards for ANPR infrastructure development and use are included within NASP Part 2 Section 7.
Compliance with NASP is indicative of compliance with Principle 2.
1. Do you review your system regularly?
Yes No
2. Have you conducted privacy impact assessments?
Yes No
3. Do you publish your privacy impact assessments and reviews?
Yes No
4. Do you feel there has been appropriate consultation in relation to your
development of ANPR infrastructure?
Yes No
5. Have you identified any areas where further action is required to more fully
conform with the requirements of Principle 2?
Action plan
Yes No
Principle 3
There must be as much transparency in the use of a surveillance camera system as possible, including
a published contact point for access to information and complaints.
1. Do you publicise the use of ANPR cameras in your area?
Yes No
2. Do you identify the point of contact for information and complaints?
Yes No
3. Does your publication of information include the procedures and safeguards
that are in place, impact assessments undertaken, performance statistics and
other management information?
Yes No
✔
✔
✔
✔
✔
✔
✔
✔
All Police camera locations are reviewed regularly with regards to volumes of data and volumes of "vehicles of interest"
to justify their continued existence.
PIAs previously conducted across Dorset by Police using Wessex FM and Dorset Echo with only positive feedback. All
available on Dorset Police website.
Publication of camera details on Blandford Forum Town Council website.
4. Do you have a complaints procedure in place?
Yes No
5. Do you make the public aware of how to escalate complaints?
Yes No
6. Is there a defined time scale for acknowledging and responding to complaints
and is this conveyed to the complainant at the outset?
Yes No
7. Do you publish the number and nature of complaints received?
(NB Police forces professional standards departments, or local equivalents, are
likely to provide for the appropriate receipt and management of complaints.)
Yes No
8. Have you identified any areas where further action is required to more fully
conform with the requirements of Principle 3?
Action plan
Yes No
Principle 4
There must be clear responsibility and accountability for all surveillance camera system activities
including images and information collected, held and used.
Standards for ANPR infrastructure development and use are included within NASP Part 2. Compliance
with NASP is indicative of compliance with Principle 4.
1. What arrangements are in place to provide clear responsibility and accountability?
2. Are all staff aware of their responsibilities?
Yes No
✔
✔
✔
✔
✔
✔
Dorset Police Website details full complaints procedures, contacts details etc
Fully NASP compliant, data is archived in a protective secure data storage with access only by a limited number
authorised Officers and Staff, with all systems audited and monitored. Authorised Officers and Staff have all been
trained.
Data will only be stored for 12 months from 1st April 2018 and then deleted.
3. Please explain how you ensure the lines of responsibility are adhered to.
4. If you share ANPR infrastructure, is it clear what each partner organisation is
responsible for and what the individual obligations are?
Yes No
5. Have you identified any areas where further action is required to more fully
conform with the requirements of Principle 4?
Action plan
Yes No
Principle 5
Clear rules, policies and procedures must be in place before a surveillance camera system is used,
and these must be communicated to all who need to comply with them.
Standards for ANPR development and use are included within NASP Part 2 and Part 3. Compliance
with NASP is indicative of compliance with Principle 5.
1. Do you have clear policies and procedures which help ensure that any legal
obligations affecting the use of such a system are addressed?
Yes No
If so please specify.
✔
✔
✔
The Town Council is the purchaser, and therefore owner, of the system and Dorset Police manages the system.
Dorset Police ANPR system is fully auditable and details all users keystrokes. The whole system is monitored and users
are dip sampled and asked to prove their justification for their use of the system. Failures to do so can result in breaches
of discipline and prosecution under the Data Protection Act or similar.
Force ANPR Policy document
Force ANPR Working Practices document
Force Control Room Policies
2. Do users receive training appropriate to their role?
Yes No
3. How do you ensure that all system users remain up to date and compliant with relevant
operational, technical, privacy considerations, policies and procedures?
4. Have you identified any areas where further action is required to more fully
conform with the requirements of Principle 5?
Action plan
Yes No
Principle 6
No more images and information should be stored than that which is strictly required for the stated
purpose of a surveillance camera system, and such images and information should be deleted once
their purposes have been discharged.
Standards for management and use of ANPR data are included within NASP Part 2 and Part 3.
Compliance with NASP is indicative of compliance with Principle 6.
1. On what basis is the ANPR data retained and for how long?
2. Do you have an auditable process for reviewing ANPR data (including images)
and managing their retention?
Yes No
3. Are there any time constraints in the event of the enforcement agency not
taking advantage of the opportunity to view the retained ANPR data?
Yes No
✔
✔
✔
✔
Regular updates to any relevant policies or procedures would be notified to all on a force wide weekly update electronic
noticeboard system.
Changes to operational systems are sent to individual users by e-mail from the system's internal list of users and
reflected in training documentation.
Majority of Dorset cameras are 3G operated and don't have images. Currently in line with Home Office NPCC and
Information Commissioner guidance, all textual data is held for 24 months. Images of innocent vehicles of no interest to
the Police are weeded from the system at 12 months with all other data deleted at 24 months.
Recent changes have brought ANPR data in line with other personal Police data and so effective from 1st April 2018, this
retention period will reduce to 12 months. System has automated filters which are set to do this.
4. Are there any time constraints which might affect external parties from viewing
the ANPR data?
Yes No
5. Do you quarantine all relevant ANPR data relating to a reported incident until
such time as the incident is resolved and/or all the ANPR data have been
passed on to official third parties?
Yes No
6. Have you identified any areas where further action is required to more fully
conform with the requirements of Principle 6?
Action plan
Yes No
Principle 7
Access to retained images and information should be restricted and there must be clearly defined
rules on who can gain access and for what purpose such access is granted; the disclosure of
images and information should only take place when it is necessary for such a purpose or for law
enforcement purposes.
Standards for management and use of ANPR data are included within NASP Part 3. Compliance with
NASP is indicative of compliance with Principle 7.
1. Do you have a policy on who has access to the stored information?
Yes No
2. Do you have a policy on disclosure of information?
Yes No
✔
✔
✔
✔
✔
3. What checks do you have in place to ensure that the disclosure policy is followed?
4. Have you identified any areas where further action is required to more fully
conform with the requirements of Principle 7?
Action plan
Yes No
Principle 8
Surveillance camera system operators should consider any approved operational, technical
and competency standards relevant to a system and its purpose and work to meet and maintain
those standards.
Standards for development, management and use of ANPR are included within NASP Parts 1, 2
and 3. Compliance with NASP is indicative of compliance with Principle 8.
1. What approved operational, technical and competency standards relevant to a surveillance system
and its purpose does your system meet?
✔
The system will automatically not allow Police officers or staff to print another force’s ANPR data for evidence without
first contacting that force for protecting DPA principles. Coupled to this, local users are all trained in disclosure of ANPR
data. Only trained and authorised Police Officers and Staff have access, currently around 350 people (14% of the force).
NASP
2. How do you ensure that these standards are followed appropriately?
3. What steps are in place to secure certification against the approved standards?
4. Have you identified any areas where further action is required to more fully
conform with the requirements of Principle 8?
Action plan
Yes No
Principle 9
Surveillance camera system images and information should be subject to appropriate security
measures to safeguard against unauthorised access and use.
Standards for management and use of ANPR are included within NASP Parts 1, 2 and 3. Compliance
with NASP is indicative of compliance with Principle 9.
1. What security safeguards do you have in place to ensure the integrity of images and information?
✔
Regular health checks of all cameras, monitored daily, twice annual visits to ensure lenses are cleaned and all ok.
Only NASP compliant cameras are purchased ensuring cameras are compliant from the start.
Only NASP compliant cameras are purchased ensuring cameras are compliant from the start.
Data is passed encrypted into the secure Police network where it is stored in a secure server with limited access as
detailed previously
2. If the system is connected across an organizational network or intranet, do
sufficient controls and safeguards exist?
Yes No
3. What is the specified purpose for which the information is being used and accessed and is this
consistent with the stated purposes?
4. Do you have preventative measures in place to guard against misuse of data
and images?
Yes No
5. Are your procedures and instructions and/or guidelines regarding the storage,
use and access of surveillance system information documented?
Yes No
6. Have you identified any areas where further action is required to more fully
conform with the requirements of Principle 9?
Action plan
Yes No
Principle 10
There should be effective review and audit mechanisms to ensure legal requirements, policies and
standards are complied with in practice, and regular reports should be published.
Standards for management and use of ANPR are included within NASP Parts 1, 2 and 3. Compliance
with NASP is indicative of compliance with Principle 10.
1. Does your system have a review process that shows it still addresses the
needs and delivers the benefits that justify its use?
Yes No
2. Have you identified any cameras that do not remain justified in meeting the
stated purpose(s)?
Yes No
✔
✔
✔
✔
✔
✔
Policing purposes
3. Have you conducted an evaluation in order to compare alternative interventions
to surveillance cameras?
Yes No
If so please provide brief details.
4. Have you identified any areas where further action is required to more fully
conform with the requirements of Principle 10?
Action plan
Yes No
Principle 11
When the use of a surveillance camera system is in pursuit of a legitimate aim, and there is a pressing
need for its use, it should then be used in the most effective way to support public safety and law
enforcement with the aim of processing images and information of evidential value.
Standards for management and use of ANPR are included within NASP Parts 1, 2 and 3. Compliance
with NASP is indicative of compliance with Principle 11.
1. Are the ANPR data and images produced by your system of a suitable quality
for the criminal justice system to use?
Yes No
2. Do you have safeguards in place to ensure the forensic integrity of the ANPR
data and images including a complete audit trail?
Yes No
3. Do you have a policy on data storage, security and deletion?
Yes No
✔
✔
✔
✔
✔
Every site is considered for a variety of options as part of the initial scoping phase. Cameras are only selected if they
meet the aim.
4. Is the information stored in a format that is easily exportable?
Yes No
5. Does the storage ensure the integrity and quality of original recording and the
meta data?
Yes No
6. Have you identified any areas where further action is required to more fully
conform with the requirements of Principle 11?
Action plan
Yes No
Principle 12
Any information used to support a surveillance camera system which compares against a reference
database for matching purposes should be accurate and kept up to date.
Standards for management and use of ANPR are included within NASP Parts 1, 2 and 3. Compliance
with NASP is indicative of compliance with Principle 12.
1. Do you have a policy in place to ensure that the information contained on your
database is accurate and up to date?
Yes No
2. Do you have a procedure for deciding when and whether an individual or
vehicle should be included in a reference database?
Yes No
3. What policies are in place to determine how long information remains in the reference database?
✔
✔
✔
✔
✔
NIM policies and guidance, PNC Policy.
Vehicles for consideration of adding to a list of "vehicles of Interest" must be assessed in a NIM compliant format and
follow appropriate review policies such as those set for automatic processing on PNC, i.e. both PNC and ANPR system
hotlists will weed vehicles at a set time period in line with current national Home Office issued guidance.
4. Have you identified any areas where further action is required to more fully
conform with the requirements of Principle 12?
Action plan
Yes No
✔
Additional Information
Additional Information
Additional Information
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Completed 9 July 2020

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