Data Protection Impact Assessment

 

Why have we produced this document?

Moving People Ltd is committed to protecting the privacy of our passengers, employees and members of the public. As part of this commitment, we have undertaken a Data Protection Impact Assessment (DPIA) relating to the use of CCTV and audio recording systems fitted to certain vehicles. This assessment considers the privacy implications of these systems and the measures we have implemented to ensure that their use is appropriate, necessary and proportionate.

 

What information is collected?

Depending on the vehicle and equipment fitted, our systems may record:

• Internal and external CCTV footage.

• Audio within the passenger compartment.

• Vehicle location information.

• Date and time information associated with recordings.

Recordings may contain images and voices of passengers, employees, visitors and members of the public.

 

Why do we use CCTV and audio recording?

The primary purposes are:

• Protecting the safety and welfare of passengers and drivers.

• Supporting safeguarding responsibilities.

• Investigating accidents and incidents.

• Verifying customer complaints and commendations.

• Investigating allegations of misconduct.

• Preventing and detecting crime and anti-social behaviour.

• Supporting insurance claims and legal proceedings.

• Assisting regulatory authorities and law enforcement agencies when required.

 

Why is audio recording necessary?

Whilst CCTV footage can show what happened during an incident, it will not always provide the context needed to establish exactly what was said.

Audio recordings can assist in resolving disputes fairly and accurately, particularly where there are conflicting accounts of events.

Examples may include:

• Customer complaints regarding driver conduct.

• Allegations of abusive or threatening behaviour.

• Safeguarding concerns involving passengers.

• Disputes where video footage alone cannot determine what occurred.

We concluded that, in some circumstances, audio recording provides evidence that cannot reasonably be obtained through less intrusive means.

 

What alternatives were considered?

We considered whether the same objectives could be achieved through:

• CCTV without audio.

• Witness statements.

• Driver reports.

• Customer statements.

• Incident reports.

 

While these measures remain important, they do not always provide an independent and objective record of events.

For this reason, Moving People Ltd considers limited audio recording to be a proportionate measure alongside video recording.

 

How do we minimise the impact on privacy?

We recognise that audio recording is more intrusive than video recording alone.

To reduce the impact on privacy:

• Audio recordings are not routinely monitored in real time.

• Recordings are only reviewed where there is a legitimate business need.

• Access is restricted to authorised personnel.

• Access to recordings is controlled and auditable.

• Recordings are securely stored.

• Recordings are automatically deleted when no longer required.

• Vehicles display signage informing passengers that CCTV and audio recording may be taking place.

 

Who can access recordings?

Access is limited to authorised personnel who have a legitimate operational, safeguarding, legal, insurance or regulatory reason to review recordings.

 

Recordings may also be shared where lawful and necessary with:

• Police and law enforcement agencies.

• Local authorities.

• Schools and safeguarding professionals.

• Insurance providers.

• Legal representatives.

• Courts and regulatory bodies.

 

How long are recordings retained?

Recordings are normally retained for a limited period before being automatically overwritten.  Where a recording forms part of an investigation, insurance claim, safeguarding concern, legal proceeding or regulatory matter, it may be retained for longer until the matter is concluded.

 

What are your rights?

Individuals have rights under data protection legislation, including the right to request access to personal data held about them, subject to legal restrictions and the rights of other individuals.  Further information can be found in our Privacy Policy .

 

Conclusion

Following our assessment, Moving People Ltd considers the use of vehicle CCTV and limited audio recording to be necessary and proportionate in pursuit of legitimate interests including passenger safety, employee protection, safeguarding, incident investigation and the fair resolution of complaints.  We remain committed to regularly reviewing our practices to ensure that privacy rights continue to be respected while maintaining a safe environment for passengers, employees and members of the public.