Sort of Fair Processing Notice

Walking through Huddersfield the other day I caught this interesting example of a fair processing notice. It was a bus shelter. The actual notice was well above the normal range of vision. (Which reminds me of an old joke. What lies on its back eight feet up in the air.  Answer later.)

But how fair is this sign? Is it a fair processing notice informing data subjects that they might be being filmed? It has the magic acronym CCTV so there’s definitely a possibility that filming is taking place. But the other words seem to confuse the issue.

Anti-social behaviour is a crime. We’re not going to disagree with that are we? but it’s a statement of fact not really what’s needed on an FPN. You might as well say that Chelsea won the Champion’s League this year.

Plain Clothes Police Officers.  So how do we know they are Police Officers? Do they wear a carnation in their lapel or are they really operating covertly? This phrase means that everyone on the streets may be a police officer. Is this fair? Or if covert operations are being undertaken why do we say that plain clothes police officers are in place. Isn’t covert er… wait for it… covert? Does RIPA ring a bell?

Or CCTV in use.  Whoa let’s take a rain check.  Either it is in use or it isn’t. If it is you put up signs saying who’s doing it, why and contact details. If it’s not you don’t. Or maybe it’s secret filming. Donnnngggg. (That’s an alliteration denoting the tolling of the RIPA bell)

Finally your behaviour could be under observation. Back to the previous paragraph. Either it is or it isn’t. If it is for general crime prevention purposes then put up signs. If it’s a covert operation pre-authorise it through your SPOC and don’t bother with signs.

And to finish off 7 (count them) individual organisations contributed to this sort of fair processing notice including some very well known ones. So 7 data protection persons gave their opinion on the poster. No-one thought it was a bit naff.   Or maybe they didn’t ask the DP persons.

Take care in Huddersfield. They might be filming you (or not). Anyone at all could be a police officer. And Chelsea won the Champions League.

Ah yes the answer to the question.

What lies on its back eight feet up in the air. A dead spider.

Author: actnowtraining

Act Now Training is Europe's leading provider of information governance training, serving government agencies, multinational corporations, financial institutions, and corporate law firms. Our associates have decades of information governance experience. We pride ourselves on delivering high quality training that is practical and makes the complex simple. Our extensive programme ranges from short webinars and one day workshops through to higher level practitioner certificate courses delivered online or in the classroom.

One thought on “Sort of Fair Processing Notice”

  1. If I was being cynical I’d say the DP Officers for the organisation both hadnt been consulted and more worryingly probably werent even made aware that this sign was being produced.

    Sadly I am basing this on experience!!

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