FOI release

BSCC-FOI-1625-HD: use of speed watch recording devices

Updated 11 November 2025

Office of the Biometrics and Surveillance Camera Commissioner
2 Marsham Street
London SW1P 4DF

7 November 2025

https://www.gov.uk/government/organisations/biometrics-and-surveillance-camera-commissioner

To: [redacted]

Letter by email

Dear [redacted],

I write in response to an email received by my office on Tuesday 21st October 2025 in which you asked:

… please… broaden my original FoI request from correspondence just about Autospeedwatch to correspondence about any speed watch recording device?

This follows our response to your original FOI request, in which you asked:

Please provide copies of all guidance you have given to Avon and Somerset Police, or the Avon and Somerset Police and Crime Commissioner, about the use of the Autospeedwatch road traffic camera for detection, recording and reporting of speeding vehicles.

Your request has been handled as a request for information under the Freedom of Information Act 2000.

We have reviewed our records, and a copy of the correspondence that pertains to your request is annexed to this letter.

It may be helpful to note that, in accordance with the Office of the Biometrics and Surveillance Camera Commissioner’s data protection policy, retention schedules for such correspondence are limited to a maximum of three years.

Furthermore, the office cannot access any former Commissioner’s inboxes, so any correspondence held within them would not be retrievable.

If you are dissatisfied with this response, you may request an independent internal review of our handling of your request by submitting a complaint within two months to the address below, quoting reference BSCC-FOI-1625-HD. If you ask for an internal review, it would be helpful if you could say why you are dissatisfied with the response.

[redacted]

5th Floor, 2 Ruskin Square
Broad Green
Croydon
CR0 2WF

e-mail: Sciencesupportfoi@homeoffice.gov.uk

As part of any internal review, our handling of your information request will be reassessed by staff who were not involved in providing you with this response. If you remain dissatisfied after this internal review, you have a right of complaint to the Information Commissioner as established by section 50 of the Freedom of Information Act.

Kind regards

Professor William Webster

Biometrics and Surveillance Camera Commissioner

Email: enquiries@obscc.org.uk

Annex of Information Held

From: Enquiries enquiries@obscc.org.uk

Sent: 26 February 2024 13:46

To: [redacted]@avonandsomerset.police.uk>; Enquiries enquiries@obscc.org.uk

Subject: RE: Deployment of Speed detection cameras by local Parish Councils

Good afternoon [redacted]

Thank you for your email to the Biometrics and Surveillance Camera Commissioner’s mailbox.

On establishing who the data owners are, please refer to the ICO and their DPA guidance as this is not our area of expertise.

Please also refer to principle 4 in the surveillance camera code of practice, particularly 4.2: Where a system is jointly owned or jointly operated, the governance and accountability arrangements should be agreed between the partners and documented so that each of the partner organisations has clear responsibilities, with clarity over obligations and expectations and procedures for the resolution of any differences between the parties or changes of circumstance. Further guidance on this is available from the ICO.

If the parish councils are purchasing and deploying cameras themselves, then they are fully responsible for compliance with the code, as relevant authorities under the Act.

The following links may be helpful to you:

Sharing personal data with law enforcement authorities, ICO

Passport to compliance - GOV.UK

Surveillance Camera Commissioner’s buyer’s toolkit - GOV.UK

CCTV checklist, ICO

Data Protection Impact Assessments (DPIAs), ICO

Kind regards,

[redacted]

Office of the Biometrics and Surveillance Camera Commissioner

From: [redacted]@avonandsomerset.police.uk>

Sent: Friday, February 23, 2024 10:00 AM

To: Enquiries enquiries@obscc.org.uk

Subject: Deployment of Speed detection cameras by local Parish Councils

Good morning,

I am employed by Avon & Somerset Constabulary to manage risk relating to data protection and privacy.

A situation has arisen where there is an increased demand from local Paris Councils to the deployment of fixed speed detection cameras as part of speed awareness and deterrent. These cameras collect registration details as well as average speed. The reads are then sent to Avon & Somerset Constabulary (where over a certain limit) who then consider whether warning letters are issued to the registered keeper via checking the details on the Police National Computer (the council do not have access to this data).

Currently, there are local Speed Watch volunteers who are deployed with mobile cameras and wear hi-vis jackets. These are only deployed in one-hour slots and only a few times a week. The details are manually recorded and then forwarded to the police for consideration of warning letters.

I must point out that in both situations this would only be warning letters and not any type of enforcement (i.e. speeding tickets). The lawful basis for taking the images is in relation to Section 39 of the Road Traffic Act 1988 and the general duty of local authorities to promote Road Safety.

The reason for my enquiry is to obtain your position as to which organisation has responsibility for the operation of these cameras and any compliance with the code of practice for deployment of surveillance cameras.

At present, the volunteers fall within the control of Avon & Somerset Police as they are deployed on mobile devices with training and signage etc. The deployment of numerous cameras which will operate 24/7 is a significant change and it is not clear to us as to who is responsible for the deployment. Our concerns relating to this deployment are:

• Cameras are not compliant with Home Office standards and there are potential issues over accuracy (speed and read of vehicle registration marker)
• Cameras will now be deployed 24/7 rather than for set time periods – although it is believed they do not work accurately in dark conditions
• Issues in how signage will be deployed
• The cameras are only small devices 30X15X15 centimetres in size

Given that there are concerns over the accuracy of the data Avon & Somerset Police do not wish to have ownership of the data as any misread will be our fault. There is also a concern that this could lead to a significant increase in warning letters, and this could be interpreted as increased surveillance in road policing. The cameras are also small and not marked up like the traditional speed enforcement cameras and the markings on the road etc.

It is not known at this time what signage will be deployed other than what they currently have regarding Speed Watch usage.

Whilst the cameras will be purchased by the local Parish Councils our concern is in relation to who has responsibility for the data as this would lead to who has to complete the Surveillance Code of Practice documents. I believe there are in the region of 10-20 Parish Councils who are interested, but this figure could increase.

Please can I have your opinion as to who you consider to be the responsible party for these cameras and therefore, who will need to complete the Code of Practice. There is a resource implication either way and some Parish Councils may struggle to complete this without assistance. Any input you can provide will be of great assistance. I am happy to be contacted again if you require further information.

Thank you in anticipation

[redacted]