Big Brother Watch
Mr Christopher GrahamInformation CommissionerThe Office of the Information Commissioner,Water Lane,Wycliffe House,Wilmslow, Cheshire SK9 5AF7
June 2011Dear Mr. Graham,
Complaint:Royston ANPR “ring of steel”
We are writing on behalf of a number of people who have complained to No CCTV, PrivacyInternational and Big Brother Watch with regard to the installation of a "ring of steel" ofAutomatic Number Plate Recognition (ANPR) cameras around the town of Royston inHertfordshire. We believe this project is unlawful.The cameras are being funded by Hertfordshire Constabulary, North Hertfordshire DistrictCouncil and Royston's Business Improvement District Royston First. The installation ofsuch a “ring of steel” in Hertfordshire is cause for particular concern as the Chief Constableof Hertfordshire Constabulary was until recently the Association of Chief Police Officers(ACPO) national lead on ANPR. You will be aware of concerns that have been raised inmany quarters about ACPO’s lack of accountability and the opaque relationships betweenthe organisation and revenue sources that operate within the ambit of its policies. ACPO’sstrong and continued support for ANPR has no legal basis or authority.We refer to your response to Privacy International’s ANPR complaint of 5
September2008 confirming that data collected by ANPR cameras is personal data. ACPO’s 'ANPRStrategy for the Police Service –2010-2013' also states:“Whilst a Vehicle Registration Mark (VRM) alone does not identify aparticularindividual, ANPR data will be treated as ‘personal data’ as defined in Article 2 of theEuropean Directive 95/46/EC.;”['ACPO in their 'ANPR Strategy for the Police Service –2010-2013', p6]Consequently this data falls within the remit of theData Protection Principles in Schedule 1of the Data Protection Act.