On Tuesday 12th and Wednesday 13th June the London Evening Standard ran articles on its website regarding the Jubilee Line strike planned for 14th June 2018 (https://www.standard.co.uk/news/transport/tube-strike-looms-threatening-chaos-for-tens-of-thousands-of-commuters-on-jubilee-line-a3861526.html) In both videos there were shots of the CCTV screens at, I think Oxford Circus, in which many LUL passengers faces were clearly identifiable. This is in clear breach of the Information Commissioners guidance and the Data Protection Act (CCTV operators are not allowed to disclose images of identifiable people to the media - or to put them on the internet - for entertainment. Images released to the media to help identify a person are usually disclosed by the police). There is an exception if required to disclose the images for legal reasons but this would not apply in this instance. I therefore ask the following questions as an FOI request; 1. What information does LUL/TfL have as to why it allowed filming in its station of CCTV images where passengers faces were clearly identifiable? 2. What information does LUL/TfL have with regard to processes and procedures that should have been in place to prevent any occurrence of CCTV image disclosure to unauthorised persons? 3. What information does LUL/TfL have about what steps it will be taking to prevent such unauthorised and illegal disclosure happening in the future? 4. What information does LUL/TfL have regarding whether it has reported it’s self to the Information Commissioner in relation to this obvious breach? 5. What information does LUL/TfL have regarding how it intends to protect CCTV screens from being visible to the public?

---

TfL Ref: 0680-1819

Thank you for your request received by Transport for London (TfL) on 13 June 2018 asking for information about CCTV screens and data protection.

Your request has been considered in accordance with the requirements of the Freedom of Information Act and our information access policy. I can confirm that we hold the information you require. You asked:

On Tuesday 12^th and Wednesday 13^th June the London Evening Standard ran articles on its website regarding the Jubilee Line strike planned for 14^th June 2018 (https://www.standard.co.uk/news/transport/tube-strike-looms-threatening-chaos-for-tens-of-thousands-of-commuters-on-jubilee-line-a3861526.html).

In both videos there were shots of the CCTV screens at, I think Oxford Circus, in which many LUL passengers faces were clearly identifiable. This is in clear breach of the Information Commissioners guidance and the Data Protection Act (CCTV operators are not allowed to disclose images of identifiable people to the media - or to put them on the internet - for entertainment. Images released to the media to help identify a person are usually disclosed by the police). There is an exception if required to disclose the images for legal reasons but this would not apply in this instance.

I therefore ask the following questions as an FOI request;

1. What information does LUL/TfL have as to why it allowed filming in its station of CCTV images where passengers faces were clearly identifiable?
2. What information does LUL/TfL have with regard to processes and procedures that should have been in place to prevent any occurrence of CCTV image disclosure to unauthorised persons?
3. What information does LUL/TfL have about what steps it will be taking to prevent such unauthorised and illegal disclosure happening in the future?
4. What information does LUL/TfL have regarding whether it has reported it’s self to the Information Commissioner in relation to this obvious breach?
5. What information does LUL/TfL have regarding how it intends to protect CCTV screens from being visible to the public?

We believe that the footage used by the Evening Standard was old footage from their archive from 2016 (based on the date from the monitors). We didn’t allow any new footage or filming for this article. We have reviewed the footage and we do not agree that individuals can be identified from the 4 seconds of footage showing multiple cctv screens and we consider that this footage would not amount to an intrusion into anybody’s private life. We have received no complaints from anyone who considers they were identifiable from the cctv screens and we do not consider that there has been an unauthorised or illegal disclosure. Therefore we will not be making a report to the ICO.

We have a number of privacy and data protection policies which provide guidance to staff about how to process personal information safely and securely. We also provide instructions and procedures to staff on specific aspects of processing personal data, and we have compulsory privacy and data protection e-learning for our staff.

If this is not the information you are looking for, please do not hesitate to contact me.

Please see the attached information sheet for details of your right to appeal.

Yours sincerely

Sara Thomas

FOI Case Management Team

General Counsel

Transport for London

Back to top

---