Buckinghamshire CC ANPR cameras

Roland Perry lists at internetpolicyagency.com
Thu Jan 12 11:51:01 GMT 2012

In article <E1RlGzD-0006vU-Sj at skipnote.org>, Chris Edwards 
<chris-ukcrypto at lists.skipnote.org> writes
>| http://ec.europa.eu/justice/policies/privacy/docs/wpdocs/2007/wp136_en.pdf
>|         "a person may be identified directly by name or indirectly by a
>|         telephone number, a car registration number, a social security
>|         number, a passport number or by a combination of significant
>|         criteria which allows him to be recognized by narrowing down the
>|         group to which he belongs (age, occupation, place of residence,
>|         etc.)".
>Does that apply to *all* processing of registration numbers ?  Or only if
>the controller can realistically turn it into a name ?
>E.g a garage collects registrations of its customers, and can turn them
>into names via it's records.  So personal data.  But the typical
>(non-government) ANPR operator may collect loads of registrations, the
>vast majority of which they are unable (as Ian notes) to turn into a name,
>as they don't have access to DVLA database.

The general rule is that unless you *know for sure* that the (eg) 
numberplates you've recorded can never be traced back to the keeper, you 
should treat them as personal data. Remember, the person who initially 
collected them isn't the only person who might later be able to use them 
to identify a person.
Roland Perry

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