APPENDIX 33
Memorandum submitted by Transport for
London
1. INTRODUCTION1.1 As
a major organisation and heavy user of over 10,000 CCTV cameras
spread across its rail network, stations and roads in London and
the fleet of 8,000 buses all equipped with CCTV cameras, Transport
for London (TfL) welcomes the opportunity to submit written evidence
to this inquiry.
1.2 TfL has a lawful obligation to provide
a safe and efficient transport system in London and as such uses
and maintains a number of data sources relating to the transport
system to meet this obligation. TfL actively works with its stakeholders,
passenger groups and the Information Commissioner to ensure that
it holds, processes and discloses information in a transparent,
proportionate, fair and lawful manner.
2. USE OF
CCTV
2.1 CCTV systems in particular are used
successfully by TfL for both transport system management and delivering
a safe and secure environment for those who travel on London's
transport system. In addition to its own rail and bus networks,
TfL has helped fund CCTV cameras on some National Rail stations
and trains serving London as well as paying the Metropolitan Police
£60 million and British Transport Police £50 million
for resources to provide a safe transport network. For example,
we use on-bus CCTV to deal with crime and anti-social behaviour
on buses and have worked in partnership with the Metropolitan
Police to deal with individuals perpetrating crime on the bus
network. This has led to over 1,000 convictions of individuals
on the bus network and helped to deliver a more safe and secure
environment for our passengers and staff.
2.2 In addition, the CCTV coverage of TfL's
network proved invaluable to the police and Security Services
in the aftermath of the incidents of 7 and 21 July 2005. It provided
valuable intelligence to the Security Services and gave vital
assistance in the investigation and prosecution of individuals
involved in the incidents. The CCTV coverage of the network remains
an essential component of protecting the system from terrorism
and providing essential intelligence to the Police and security
services to support this.
3. WORKING WITH
OTHER AGENCIES
3.1 TfL also works with the police services
in London in order to assist with the investigation of crime and
disorder on and around the network and will, where it is lawful
provide data to assist the police to investigate crime. There
have been a number of recent high profile serious crimes that
have been successfully solved with the assistance of data provided
by TfL. There are clear procedures in place to govern the transfer
of such data and ensure that any transfer is undertaken in a manner
that is transparent, proportionate, fair and lawful.
3.2 TfL takes its responsibilities as the
Data Controller of the personal data and CCTV images of our passengers
very seriously and will not release data without careful consideration
of the implications for Londoners. However, where the release
can be undertaken in a transparent, proportionate, fair and lawful
way and will benefit London—particularly by making a direct
contribution to the safety and security of our passengers—we
will work with partners to ensure that this is delivered effectively.
3.3 Our procedures are developed using legal
advice, guidance from the Information Commissioner and our approach
has been ratified by TfL Board. We continue to develop these procedures
and protocols and they will be continually reviewed in line with
case law, legal advice, and any updated guidance that is issued
by the Information Commissioner. The bus operators who control
in excess of 50,000 on-bus cameras have strict procedures that
are agreed with TfL on handing the data and any disclosures made
to the police and law enforcement agencies is done a transparent,
proportionate, fair and lawful way. These procedures are regularly
reviewed by TfL in line with our own. The operators receive regular
visits to ensure compliance with these. We strive to balance the
benefits we can deliver to our passengers with regard to safety,
security, reliability and service responsiveness with the important
privacy demands of our passengers.
3.4 In a TfL survey (carried out by MORI)
of 1,003 respondents in December 2006, 87% of people said they
supported increasing CCTV coverage and believe it will help to
improve passenger safety on trains and in stations.
4. CONCLUSION
4.1 Overall, TfL believes that the use of
CCTV data in a transparent, proportionate, fair and lawful manner
allows us both to effectively protect our passengers and staff,
and information about them, and provide a more safe, reliable
and effective transport system for London.
April 2007
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