Request ID: FOI-0150-2324 Date published: 09 May 2023
You asked
Subject Access request for all video footage and still pictures pertaining to vehicle xxxx dated today, 12/04/2023.
A PCN, numbered xxxx was issued for a vehicle with the registration mark xxxx, date of notice 25/03/2023. In the PCN it is stated that: 'Transport for London believes that a penalty charge is payable with respect the above vehicle for the following alleged parking contravention: 62 parked with one or more wheels on or over a footpath or any part of the road other than a carriageway.'
Please note that: 'Within Greater London, Paragraph 7(2) in Schedule 1 to the 1996 Act requires that, in order for a record produced, or measurement made, by a prescribed device used for bus lane enforcement to be admissible at traffic adjudication proceedings, the device must be of a type approved by the Secretary of State.
The 2022 Regulations include provisions for the production of evidence from Closed
Circuit TV (CCTV) cameras and associated recording equipment. Such devices, or parts of
a device not covered by an existing recognised approval, must be certified by the
Secretary of State to show that the complete system is an "approved device” in order for it
to be used for the civil enforcement of road traffic contraventions.'
In the PCN received from TfL it is stated that: 'The alleged contravention was seen and recorded by camera operator number 130 who was observing real time pictures from an approved device at the time stated and has been recorded on digital storage media.'
Under the Freedom of Information Act 2000 I would like you to provide me with the relevant certifications of all the equipment, camera/imaging and outstation equipment used to to issue the above mentioned PCN. Also, I would like you to provide me with the manufacturers name, serial number and date of fabrication of the camera used to record the real time pictures of xxxx at the specified location and time. I would also like to know whether the camera/imaging device and/or the outstation equipment has been modified in any way, shape or form since it's original installation.
I would also like to see certification for the following elements in the Camera Enforcement Station:
1. Video/data recording equipment
2. CCTV camera controls and systems
3. Observation/recording facilities
4. Review and image capture facilities
5. Data entry/edit facilities
Please provide me with a copy of the Technical Construction File that was submitted to the Secretary of State to gain the relevant certification for all the elements mentioned above.
We answered
TfL Ref: FOI-0150-2324
Thank you for your Freedom of Information request received by Transport for London (TfL) on 12th April 2023 asking for information about road traffic cameras.
Your request has been considered in accordance with the requirements of the Freedom of Information Act and our information access policy.
Specifically you asked:
“Under the Freedom of Information Act 2000 I would like you to provide me with the relevant certifications of all the equipment, camera/imaging and outstation equipment used to to issue the above mentioned PCN. Also, I would like you to provide me with the manufacturers name, serial number and date of fabrication of the camera used to record the real time pictures of WR08OUY at the specified location and time. I would also like to know whether the camera/imaging device and/or the outstation equipment has been modified in any way, shape or form since it's original installation.
I would also like to see certification for the following elements in the Camera Enforcement Station: 1. Video/data recording equipment 2. CCTV camera controls and systems 3. Observation/recording facilities 4. Review and image capture facilities 5. Data entry/edit facilities
Please provide me with a copy of the Technical Construction File that was submitted to the Secretary of State to gain the relevant certification for all the elements mentioned above.”
I can confirm that we hold the information you require.
Confirmation of the certification of the TfL Red Route cameras is available via the following link:
In accordance with section 21 of the FOI Act, we are not obliged to supply you with a copy of the requested information as it is already accessible to you elsewhere.
The camera at the location cited is a Bosch Model MIC IP Starlight 7100i. It was installed on 21 December 2022. Its serial number is 044624527723131017. No modifications have occurred since installation.
In regard to the request for Technical Construction Files (TCF), this information is exempt from disclosure under sections 31 (law enforcement) and 43(2) (commercial prejudice) of the Freedom of Information Act. The rationale for this is explained below.
Information about the Digital Traffic Enforcement System (DTES) that we use to enforce all types of red route traffic contraventions is available on our website via the following link: https://tfl.gov.uk/corporate/publications-and-reports/red-routes. However, we do not release specific details of the TCF as this includes the architectural design of the whole system, including in relation to security. The supporting documents are the property of SEA (who provide the maintenance and design of the system) are all considered commercially confidential.
If disclosed, the material would provide SEA’s competitors full vision of the DTES system, which would undermine their future commercial position by giving their competitors an unfair insight into their operations. Release would also reveal to the public exactly how the enforcement system works, resulting in a significant risk to the physical security of the DTES enforcement system. The TCF documents detail all the design features of the system, essentially setting out in detail exactly how the enforcement system and each of its components operates. In the wrong hands, this knowledge could potentially be used to attempt to circumvent or disrupt the system. Whilst we make no suggestion that you would use this information for anything other than you own personal interest, disclosure of information under FOI is considered to be to the world at large rather than the individual applicant. Both of these exemptions are subject to consideration of the “Public Interest Test”, which requires us to assess whether the public interest in applying the exemption outweighs the public interest in disclosure. In this instance, it is considered that the public interest favours maintaining the security and integrity of the network rather than releasing information which could present a significant risk. There is also no public interest in TfL disclosing commercially prejudicial information, which could bring TfL into dispute with our supplier and potentially a breach of contract, with the associated costs that would bring. This is further supported by the fact that information about the DTES to help the public understand its operation and use is already proactively published via the link given above. For these reasons we believe the balance of public interest rests in the exemptions applying.
Please see the attached information sheet for details of your right to appeal as well as information on copyright and what to do if you would like to re-use any of the information we have disclosed.
Yours sincerely,
David Wells FOI Case Officer FOI Case Management Team General Counsel Transport for London
