Below is more about the issue of CCTV.

‘Regardless of the size of the system, you should initially consider achieving your outcome using alternative, less privacy intrusive methods. You may consider that new technology is an attractive or affordable solution. However, the use of surveillance systems should be a necessary and proportionate response to the problem you are addressing. You should therefore carefully consider whether or not to use a surveillance system, if other options are available.’

The arguments for the CCTV surveillance in the library will no doubt be to reduce crime and protect the public. These are of course legitimate reasons for using CCTV. They are far from the only ways to achieve these objectives. A good proportion of those using the library will be reading very sensitive information, and/or have sensitive personal information in documents which if they are captured on video are very intrusive and bring considerable risks if the CCTV is abused. Whatever the potential gains in terms of public protection, the general public are not the only people who misbehave. So do a proportion of local Govt councillors, executive team members and staff, right across the country – we have all too many examples of this as evidence.

‘You should carefully consider whether it is appropriate to use a surveillance system, and assess any potential impact this may have on the rights and freedoms individuals have under data protection law.’

‘It is also important that you identify an appropriate lawful basis under the UK GDPR and DPA 2018. You should clearly document and justify your reliance on a particular lawful basis in conjunction with the principles of data protection law prior to any deployments.’

‘As previously mentioned, for the use of surveillance systems you must perform a DPIA for any type of processing that is likely to result in a high risk to individuals. This is a legal requirement and applies in most cases, due to the inherent privacy risks involved in the use of surveillance systems as a type of processing.’

Your writer finds it very hard to see how having Customer Services and Opportunity Goole in the library with all the sensitive conversations that take place and highly sensitive personal information being disclosed, with members of the public who are choosing books to borrow able to hear every word could pass a Data Privacy Impact Assessment, even before you bring filming on CCTV into the equation. No doubt there will be a defence that there is a room available for privacy? So why do so few people seem to use it given what can be overheard while choosing books or sitting at tables? 

‘By installing surveillance systems in areas where people have greater expectations of privacy, you may inadvertently increase the intrusion on their private life, especially where their behaviour is not modified. The use of surveillance systems in public spaces may also have a chilling effect on the way in which people behave, interact with each other, or the places that they choose to move freely. It is important that you also consider these issues when planning to use new or existing systems and whether they can be justifiable set against the purpose(s) for the processing.’

The CCTV most certainly does intrude on the privacy of those accessing or displaying sensitive personal information in the library, at customer services, and at Opportunity Goole. They can’t modify their behaviour if they don’t know that they are being recorded. Given how unapparent the signage is, and its minimalist the general nature, it’s likely few members of the public realise they are being recorded in film, and if they do, the extent of it.

‘If you operate a surveillance system you are likely to collect personal data directly from the individuals you monitor. As a result you need to comply with data protection law, in particular Article 13 of the UK GDPR. This means you need to find a way to provide them with information about the surveillance. In any case, you must let people know when they are in an area where a surveillance system is in operation. You can also back up messages with an audio announcement, if public announcements are already used, such as in a train station or onboard public transport.’

‘An effective way to provide transparent information is to place signs prominently before the entrance to the system’s field of vision and reinforce this with further signs inside the area. You should position information at a reasonable distance from the places monitored, and in such a way that individuals can easily recognise the circumstances of the surveillance before entering the monitored area.’ 

The next quote is so important in the context of Goole library and the potentiall sensitive information that the public are likely to be looking at or showing – eg at Customer Services and Opportunity Goole…

‘FOR EXAMPLE, IT IS NOT CONSIDERED FAIR FOR AN INDIVIDUAL TO READ A SIGN THAT WARNS THEM ABOUT PARTICULARLY INTRUSIVE SURVEILLANCE TECHNOLOGY IN THE AREA, IF THE SYSTEM HAS ALREADY CAPTURED THEM WHILST READING IT.’

The actual library users may also be accessing highly sensitive information in printed material such as books and online either on their own devices, or the public computers. The books and online information  they might be looking at could be about physical health, mental health, financial problems. Somebody could be looking at information about a mental health condition, a relationship problem, a sexually transmitted disease, contraception, an addiction. They may not yet be ready to discuss it with anyone else. Goole is quite a small town. What if somebody is learning about a sexual health problem, and the East Riding Council staff looking at the CCTV film, but the library customer does not realise that staff members they know are watching them reading and can see what they are reading?

In every community there are plenty of people who love minding other people’s business and expressing their views on how other people should be running their lives better, and the more public the space they are talking, the more they love expressing their opinions. When they have had a few sherberts at a hostelry or eatery, they can be particularly talkative and forthright.

The fact that people are being filmed reading such sensitive information, and the fact that council customer services and opportunity Goole, with the sensitivity of documents likely on show are in the area being filmed means the CCTV in the library is potentially very intrusive with significant risks to people’s privacy on very sensitive matters.

Most library users are unlikely to see any of the generic signs about CCTV unless they look at the multi-sign noticeboard in the computer area at the back of the library. By which time they are already under surveillance. Those going straight to customer services and Opportunity Goole are unlikely to see a sign at all. The two signs in windows facing out into the street give the impression that it is the street that is subject to CCTV rather than the library. The library is very much more sensitive from a privacy point of view than the street. It should be absolutely clear that CCTV is in operation in the library, what can be seen, who has access to it, that a Data Privacy Impact Assessment has been carried out, what risks have been identified and what mitigations and safeguards are in place. It will not be surprising if East Riding Council strongly disagree, with criticism about red tape and a rights culture, but the above is how to treat the public fairly and with respect. Individual rights are very important, despite the concerted attacks on them by some.

Individuals should not have to ring East Riding Council, and identify themselves, to find out more they should be given clear information before they enter the surveillance area given the senstivity of some of the information accessed and on display for capture by CCTV.

There are legitimate arguments that CCTV helps tackle crime. It is not the only means of addressing crime, and putting the public under extensive surveillance should not be the default way of tackling crime. Investigating crimes effectively, and gathering evidence which leads to convictions in court, is the way to tackle crime. The fact that the retailers of Goole experience a lot of theft, which threatens their viability when times are already very challenging, suggests two things.  Firstly, that crimes are not being detected effectively (not a criticism of the Police, they may not have adequate resources). Secondly, either that CCTV is not being properly monitored, or that crime detection is not what the CCTV is being used for.

The fact that the two street window signs are at shin level, and the sign by the entrance is not only at left side shin level but largely obscured by the automatic doors for those entering the library. As I said in the previous update, that suggests East Riding Council is raising its middle finger to the spirit of Privacy and Data Protection law, and the ordinary residents.

The situation with CCTV has strengthened your writer’s feeling, based on observations of behaviour and attitudes, that East Riding Council, Goole Town Council and the Town Deal Board is an alliance of ‘monsters which are out of control’ and the instruments of a chumocracy which runs things in its own interests to the detriment of ordinary citizens. I fear that the elected mayor which is being forced on us in a very undemocratic fashion will make things worse given the risk of a big ego  with a strong taste for power and control, determined to impose their and the chumocracy’s will on everyone else, getting the job.

In saying the above I’m not denigrating the good that business small and large contributes to Goole and the wider world. I’m not denigrating those who have worked very hard to bring new businesses to Goole, and encourage entrepreneurs to found small businesses. Of course it contributes to prosperity. Having a lifelong interest in the engineering aspects of railways (though no professional expertise or ability) I’m pleased beyond what I can describe that Siemens has created a centre of excellence here.

Siemens have brought the world, among other marvels,  the Velaro high speed trains which operate some of the Eurostar services; The Eurosprinter, Taurus and Vectron locomotives, and Viaggio Comfort carriages (sadly the locos and carriages don’t operate in the UK, but hope springs eternal). I am a Siemens fan. I have a copy of the book of Werner von Siemens recollections.

The way East Riding Council and Goole Town Council have treated the established part of Goole and its residents has destroyed the considerable goodwill that bringing a rail centre of excellence to the town, and the way the refuse collectors and street cleaners serve us, to give two examples, generates.

Business is important, and generates a lot of benefits. It is not everything though. Every community is made up of a variety of people, and contributions to the wider good, not all of which can be measured by the yardstick of hard cash. There needs to be a balance. In Goole and the wider world things are badly out of balance. Many small and medium businesses suffer as much as non-powerful members of the public.

The above is an East Riding matter, it is cultural, it is outside the power of the library staff.

Most of us, while we have particular values, but we are not devotees of any political party. We just want common sense. Anybody who wants power and control should be viewed with great caution. Their power needs to be limited, they must be challenged, transparent and held to account. Being too trusting of those who hold power is unwise, and dangerous. Sub-postmasters, the Archbishop of Canterbury resignation, Nightingale hospitals which cost a huge amounts of money but were never used because the funding wasn’t provided for staff, weapons of mass destruction, leasehold flats, cladding…

Data Protection is not an obviously exciting issue. It needs effort to understand. It is very important though for those who do not have power, and are at risk from those who do. Given the extent to which East Riding Council control the public narrative in Goole, these updates are a way of offering alternative points of view which the two councils make significant efforts to suppress.

There is quite a lot of further information, which is where the above quotes come from, here: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/cctv-and-video-surveillance/guidance-on-video-surveillance-including-cctv/

There is also a regulator for biometrics and surveillance cameras: https://www.gov.uk/government/organisations/biometrics-and-surveillance-camera-commissioner