Few things excite more local interest on hyperlocal websites than crime – in the last couple of years the police have started to publish crime maps ward by ward. But in general these are at too high a level to be of real use on the ground. If i want to campaign as an active citizen in the big society for better policing on a particular corner or in a playground or outside a train station I need to see the real data about the crime happening there to make my case. The police are usually only too willing to tell me when and where a murder has happened with a notice through the door or a yellow incident board.
However there is a tricky balance to be struck with protecting victims – it is clearly invidious and potentially harmful to report with millimetric precision the location of say an elderly vulnerable person who has been the vicitm of dsitraction robberies in her home.
From the perspective of a local activist, it seems that aggregating crime data to ward level is overkill. In London the Met has begun quietly to release some sub ward data. This Autumn will see a further deabte about the granularity of crime data. So i thought it helpful to re-publish the Information Commissioner’s guidance on data protection and crime data from 2008 – he released it to the media in 2008 but it can be surprisingly hard to turn this up. It will be interesting to see if the risk-reward ratio has changed any as a result of practice and experience over the years. And indeed whether police information management can now strip out sensitive information at the touch of a button.
Declaration – in 2008 i was an official in Cabinet Office working on freeing up government data including crime maps – but this is the first time i have seen this guidance, which was recently passed to me. I am also on the Local Public Data Panel.
|Tony McNulty MP
Minister of State for Security, Counter-terrorism, Crime and Policing.
2 Marsham Street
5 August 2008
I am writing to you about the recent Home Office announcement that police forces will develop and publish crime maps across England and Wales. The ICO is interested in the development of this work as – depending on the nature of the mapping undertaken – there are some significant privacy issues arising by virtue of data protection legislation. The purpose of this letter is to alert police forces to the risks and to indicate safe ways forward.
My office met with the Metropolitan Police Service (MPS) and the Greater London Assembly (GLA) in July to discuss the crime mapping proposals for London. I thought it would be helpful now to outline the view we provided to the MPS in this open letter to you. I am copying this letter to the Presidents of ACPO and ACPOS asking them to circulate it to their members. This should enable the proposals to develop as consistently as possible, taking privacy concerns fully into consideration.
As a general point, one of the ICO’s key concerns is that organisations should balance the potential degree of intrusion into the privacy of victims against the likely benefits. We fully appreciate the benefit of crime mapping as a tool to assist police in carrying out their functions. We also acknowledge that publishing details of crimes may increase transparency concerning policing and enable closer community working. My office’s concern is that in, publishing details of crimes to the public at large, proper regard is had to the need to strike an appropriate balance between such public policy objectives and the privacy of victims.
Lower super output areas
We advised the MPS and GLA that reporting crimes on a â€œpoint data mappingâ€ basis – i.e. where the specific location of the offence is shown – was likely to present data protection concerns, especially where publication of any information could be readily used to identify individual victims of crime. This is of particular concern when it may lead to the disclosure of sensitive personal information about those individuals, for example whether they had been the victim of a racially motivated crime or a sex crime. I am pleased that the MPS and GLA have taken our comments on board and have developed an approach which we believe builds in suitable data protection safeguards. Specifically, they will limit reporting on crimes such as theft or burglary or motor vehicle crimes to â€œlower super outputâ€ areas which contain a minimum of 400 dwellings (approximately 3 streets). The numbers of crimes reported may be small e.g. 1 or 2 crimes in any month. However this approach significantly broadens the area to which the information relates so as to minimise the risk of any intrusion into personal privacy.
We also discussed with MPS the dangers of lower super output reporting in relation to, for example, racially motivated assaults or sexual offences. Even with reporting areas defined in this way, this may still be regarded as intrusive where the offence relates to a single incident of rape or sexual or domestic violence. Where these types of crimes occur there is likely to be more local interest, and more potential for someone to try and identify an individual. It may also be easier to identify the individual victim where they have visible injuries at the same time as the reported crime. In this type of crime we would therefore suggest that a higher threshold to safeguard personal privacy is justified. Here, we have suggested to the MPS that continuing to report at a higher level, for example by ward, would be a suitable way forward.
Individual police forces will be the data controllers for the crime maps as they will be determining the manner and purposes for which data is used and will be responsible for all the processing. It is essential, therefore, that each force is satisfied that any processing they undertake in this regard is necessary to deliver their functions. The MPS intend to consult with victims of crime on the proposals and this is certainly something the ICO would encourage. This will help to build a clearer picture of whether reporting in this way is likely to cause any individual privacy concerns which have not yet been identified by the parties involved. This will also allow forces to consider how to make victims of crime aware of the fact that the MPS undertakes this type of processing. Any legitimate objection by a victim should certainly be taken fully into account before details of that crime are published on a crime map.
Other demographic information
In terms of reporting other demographic information in conjunction with a crime map, we would advise against any additional information being published on any crime where the incidences fall below three. Small numbers of crime, coupled with profiles on race, age or sex, may easily lead to personal identification. Additional information such as this should certainly not be published where it relates to, for example, racially motivated assaults or sexual offences.
Point data mapping
Turning to ‘point data mapping’ (where the specific location of the offence is shown) the police may use their discretion to release such information in a particular case in response to an individual enquiry, where they believe there are legitimate reasons for doing so and these reasons outweigh any privacy issues. However, reporting point data mapping on the internet has significantly broader privacy implications and it would be similar to responding to a freedom of information request. Each police force would need to be satisfied that there was a public interest in making the information available to the public at large e.g. releasing details would be justified if it was with the intention of catching a criminal in association with a specific crime. It is unlikely that the public interest and benefit of sharing point data mapping information would outweigh the risk of intrusion to the individual; particularly where the benefits realised may not be significantly greater than those obtained through providing information at street or higher level. Whilst I appreciate that these types of reporting models are used in the United States, they are arguably applied to a very different landscape. For example, Chicago and New York both contain large volumes of apartment blocks, each of which often holds over a 100 apartments, making the risk of personal identification significantly lower.
I hope that the above guidance assists as this work develops, and my office is of course able to provide advice on any specific data protection issues.
As well as ACPO and ACPOS, I am copying this letter to Victim Support and releasing it to the media.
Sample letter to ACPO
Mr Ken Jones, President, Association of Chief Police Officers (ACPO);
Mr Colin McKerracher, President, Association of Chief Police Officers in Scotland (ACPOS);
Gillian Guy, Chief Executive, Victim Support.
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