Bus CCTV

Summary

The Department of Infrastructure provided details on bus CCTV camera locations, recording policies, and data retention periods, but refused to disclose specific standalone budget figures for CCTV as they are integrated into total bus costs.

Key Facts

• Side cameras on buses generally do not record imagery, while all other installed cameras do.
• CCTV data is automatically overwritten approximately 4 weeks after recording unless copied for viewing.
• Recorded imagery is stored on the Isle of Man and shared with third parties only under Data Protection Act principles.
• The Fair Processing Notice is available online and on bus notices rather than as a separate document.
• Specific budget data for CCTV alone was withheld because costs are included in total new bus costs.

Data Disclosed

• 10
• 8
• 7
• 4 weeks
• 2017-05-10
• 2017-05-26
• 2002

Exemptions Cited

• Section 20(2)(b) - Information accessible to applicant by other means
• Section 11(3) - Practical refusal reason (a) - Information not held

Data Tables (1)

Full Response Text

While our aim is to provide information whenever possible, in this instance we are unable to provide some of the information you have requested; the reasons and statutory exemption sections are shown as part of the corresponding answers below.

Response to your request

1. Please see the lists below for the locations of installed cameras on our current fleet of service buses. You may also find it useful to look at the

Manufacturer Number of cameras Location Volvo Wrights 10 Forward, rear, left side, right side, door entrance, front internal lower saloon, back of internal lower saloon, front of upper saloon, middle of upper saloon, back of upper saloon. Mercedes Citaro 8 Forward, rear, internal front, internal middle, internal back, door/entrance. Mercedes Citaro K 8 Front, rear, left side, right side, entrance door, internal front, internal middle, internal back. Mercedes City 45 7 Front, rear, left side, right side, front and rear internal, door entrance. Wrights Streetlite 8 Front, rear, left side, right side, three internal cameras, door entrance.

1. As a general rule side cameras do not record imagery. All other installed cameras record data.

2. Our CCTV website constitutes the Fair Processing Notice for Transport Services and is available via the links below. For this reason, we are not obliged to supply the information separately within this response. For information, the website is currently in process of being updated.

Under section 20(2)(b) an absolute exemption applies, information accessible to applicant by other means – information is taken to be reasonably accessible if – it is available on the internet or from any other reasonable accessible source.

https://www.gov.im/about-the-government/departments/infrastructure/isle-of-man-public- transport/cctv-policy/

https://www.gov.im/about-the-government/departments/infrastructure/isle-of-man-public- transport/cctv-policy-faqs/

1. Unless it has been copied for the purposes of viewing (those allowable within the Data Protection Act), old data are automatically overwritten when the CCTV’s internal storage has reached capacity. This generally happens at around 4 weeks after a CCTV image has been recorded.

2. Bus Vannin only shares CCTV information within the principles of the Data Protection Act 2002 (DPA). See CCTV Policy and CCTV Policy FAQs for circumstances under which CCTV information may be released to other organisations.

3. Recorded imagery is held on the Isle of Man. Information which has been shared with a third party, such as an insurance company, would still be protected by either the Data Protection Act, or equivalent privacy legislation.

4. As mentioned in Answer 3, the webpages referred to constitute our fair processing notice.
   Links to these are on notices in each bus with installed CCTV equipment.

5. We are unable to supply this information in the format you have requested. This is because we do not have a separate budget for CCTV alone. Installation, warranty and first maintenance of CCTV is included in the total new bus costs to us. Costs connected with maintenance of CCTV on older buses where this is not the case, are shown in the table at Appendix 1.

Under sections 11(3) practical refusal reason (a) of the Act, in this instance the Department does not hold… specific information to answer your question. Your right to request a review

If you are unhappy with this response to your Freedom of Information request, you may ask us to carry out an internal review of the response, by completing a complaint form and submitting it electronically to foi.doi@gov.im or by delivery/post to Mr Ian Harris, Department of Infrastructure, Sea Terminal Buildings, Douglas, IM1 2RF. An electronic version and paper version of our complaint form can be found by going to our website at https://www.gov.im/about-the-government/freedom-of-information/

Your review request should explain why you are dissatisfied with this response, and should be made as soon as practicable. We will respond as soon as the review has been concluded.

If you are not satisfied with the result of the review, you then have the right to appeal to the Information Commissioner for a decision on;

1 Whether we have responded to your request for information in accordance with Part 2 of the Freedom of Information Act; or

2 Whether we are justified in refusing to give you the information requested.

In response to an application for review, the Information Commissioner may, at any time, attempt to resolve a matter by negotiation, conciliation, mediation or another form of alternative dispute resolution and will have regard to any outcome of this in making any subsequent decision. More detailed information on your rights to review is on the Information Commissioner’s website at: www.inforights.im/

Should you have any queries concerning this letter, please do not hesitate to contact me.

Further information about Freedom of Information requests can be found at https://www.gov.im/about-the-government/freedom-of-information/

APPENDIX 1