General Data Protection Regulation (GDPR) requires data from digital CCTV systems should be protected taking into account the risk, cost, benefit and state of the technology. When you disclose CCTV either directly to a data subject in response to a Subject Access Request or when sending CCTV footage to a Data Processor such as ourselves for redaction of 3rd party data the files you send should be protected. The first in the list of possible controls for protecting subject data is data encryption. In this video we show you how to perform data encryption with Open Source software.
Our video redaction service enables you to disclose CCTV evidence compliant with GDPR legislation. We will obscure the identity of all persons except the person making the Subject Access Request. This usually involves blurring or pixelating other people recorded in the footage. We have over a decade of experience in video redaction and will help you to ensue that your business meets its data protection obligations when disclosing CCTV recordings.
One point of note is that in our guide we recommended that you encrypt all files even if your CCTV player DVR (digital video recorder) application is password protected. You may therefore feel that it’s not necessary to encrypt the CCTV files. If you decide not to encrypt the CCTV files then you must be certain that the video files themselves are actually encrypted. In some cases the the access password is for the DVR player software rather than the CCTV data. If you aren’t sure then encrypt it anyway. We would still require the photograph of the Data Subject and the redaction instructions to be encrypted.
Why is data encryption necessary?
GDPR strengthens the existing Data Protection Act legislation. Principle 7 of the DPA says “Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.” At the time of writing (April 2018) the ICO are working on publishing updated information about data security. When that is available we will update this post. Link to current ICO information about data encryption.
In this guide video we used 7-Zip software for Windows. Other software is available to perform similar tasks. Link to 7 Zip.