In this self explanatory letter, I ask the Surveillance Camera Commissioner Tony Porter whether the proposed new category of ‘Bulk Personal Dataset’ applies to ANPR and whether the intelligence agencies have a copy of all our journey data as part of the 10 billion reads a year ANPR system. If this were to be the case then, paradoxically it would provide for the first time some strong statutory oversight of ANPR, albeit only for a copy of it, not the original system itself.
Dear TonyAn activist working on the draft Investigatory Powers Bill scrutiny has alerted me to the category of data sets defined in the draft IP Bill as ‘Bulk Personal Datasets’. I attach the Factsheet sheet.‘A bulk personal dataset (BPD) is a dataset containing information about a wide range of people, most of whom are not of interest to the security and intelligence agencies. Lists of people who have a passport or a licensed firearm are good examples of a BPD – they includes a large amount of personal information, the majority of which will relate to people who are not of security or intelligence interest.’As 99.9999 % of ANPR will relate to innocent people it seems superficially to fit.It isn’t clear to me if the agencies have a copy of the ANPR data, similar to the so-called ‘Olympic Feed’, apparently a copy of the entire national data set that the Metropolitan Police creates and stores for serious crime and CT purposes.I understand that the agencies take a copy of the congestion charge data so i presume that there is a chance that NTAC (or whatever it is called now) or similar have a copy of ANPR.Can I ask you1. whether the agencies do take a copy of ANPR and2. whether that would be classed as a BPD, in your opinion?I note that if a copy of ANPR is held by the agencies and is BPD-classified then paradoxically, it would then have a far stricter oversight regime than the system from which the copy is taken, the ANPR system of systems held by the police.I should be grateful for your views on this matter. I am publishing this email on my website https://talkaboutlocal.org.uk/blog/Can I take this opportunity to wish you a happy Christmas.YoursWilliam Perrin
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