The use of BWV by law enforcement will often be in connection with a crime being committed. This type of personal data is likely to be particularly private and therefore should be treated with particular care. Additionally, there will be frequent occasions where footage will show victims, potential witnesses, suspects or other third parties in a state of distress. The proximity and vantage point of cameras may also increase the level of privacy intrusion, for example recording footage from within someone’s home.
In respect of BWV, the ICO’s CCTV code of practice states:
Because of the volume of personal data and potentially sensitive personal data that BWV cameras will process and the portability of them, it is important that you have appropriately robust technical and physical security in place to protect this information. For example, make sure devices can be encrypted, or where this is not appropriate have other ways of preventing unauthorised access to information.
Technical guidance from the Home Office on body worn video includes the warning that:
some suppliers may erroneously claim files are encrypted when they are in reality recorded in a non-standard format.
The data controller must also consider the security of footage once transferred from the device for long-term storage and its accessibility in response to a subject access request.