5.3.5 CCTV & Dashcams
Prior to use of a CCTV or Dashcam system it must be inspected and approved by an authorised officer of the licensing authority. Clear signage, clearly visible from the passenger seats, must be displayed within the vehicle to advise passengers that recording is in operation and advise that images and sound are being recorded and for what purpose. The details of the data controller of the system, including a contact number, should also be clearly displayed.
The Data Controller is under a legal obligation to ensure that all Data Protection requirements are fulfilled. For the avoidance of doubt, Aberdeen City Council, as the licensing authority is not the Data Controller in respect of CCTV or Dashcam systems installed by licence holders, their drivers, or their insurers. Independent legal advice should be sought prior to the installation of any system.
5.3.5.1 External (Accident) Recording
The licensing authority may permit the installation and operation of CCTV or Dashcams in taxis and private hire cars in respect of external image recording, for the purpose of accident event recording (in relation to insurance claims) and to assist with the prevention, detection and prosecution of crime. External audio recording is not permitted.
5.3.5.2 Internal (Incident) Recording
The licensing authority may permit the installation and operation of CCTV in taxis and private hire cars in respect of internal image recording to improve passenger and driver safety and for the prevention, detection and prosecution of crime. Internal audio recording is not permitted except by way of a “panic button”, which may be pressed by the driver to record audio only on the occurrence of an incident.
5.3.5.3 Data Protection Policy (Mandatory Requirements)
The licence holder must have a data protection policy which explains why CCTV or a Dashcam is necessary and what controls will be used to ensure the secure storage and processing of data recordings. It should also specify the standard retention and regular secure data disposal procedures.
5.3.5.4 Specification of CCTV or Dashcam systems
- Wiring of the CCTV/Dashcam system must be compliant with current British Standards.
- CCTV/Dashcam cameras must be permanently wired and turned on and off by the ignition only. They cannot have a switch to be turned on or off manually or be powered by a dashboard cigarette lighter.
- The storage system for recorded data should be solid state (hard drive) and of sufficient reliability, preferably with industrial grade memory. Where the storage of recorded data is on removable devices such as computer discs, SD cards or suchlike the data controller/licence holder must have satisfactory safeguards for the secure processing, storage and ultimately disposal of the data in accordance with this policy and the CCTV condition of licence. It is recommended that where removable storage is utilised the system is kept in a lockable box or compartment to prevent theft or unauthorised access.
- Stored recorded data must be encrypted and only be accessible to the data controller.