Why we use it
Body Worn Video (BWV) equipment is used by enforcement agents acting on behalf of Marston as it reassures customers and other affected parties that conduct of enforcement agents is appropriate by recording it. Being open through the use of BWV equipment allows us to be accountable for our actions. This is particularly useful when resolving disputes or preventing poor conduct in the future.
We recognise the right to privacy and try to respect these rights in how we use BWV equipment and having regard to the requirements of the UK Information Commissioner’s Office.
How we train enforcement agents on the use of Body Worn Video equipment?
Enforcement agents acting on behalf of Marston are trained to use BWV properly.
During the course of an on-street visit
Enforcement agents record every visit unless specific circumstances occur where they are required to switch off the BWV. From time to time, the BWV may be unavailable, for example, if it is under repair or if there is a fault on the camera.
Our equipment is never used in a hidden or covert manner. We use it so that all parties will know that a record of the visit is being made.
When meeting customers, enforcement agents acting on behalf of Marston will explain who they are and the reasons for the BVW being used. The equipment clearly displays “recording in progress” in large letters to ensure customers know that recording is in progress.
We try to make sure children are never filmed. Where children are present, the enforcement agent will ask if the conversation can be moved into another room or that the child is taken to another room. If the child cannot be taken into another room, the enforcement agent will continue to film but focus the camera away from the child.
If, while operating the BWV, a customer asks for the camera to be turned off, our enforcement agent will comply with the request, unless:
- he/she is being threatened and/or verbally abused in any way; or
- he/she is being attacked or abused.
If the permission to film is withdrawn, enforcement agents turn off the BWV and cease filming. However, if one of the adverse conditions listed above occurs, then they may turn the BWV back on, and leave immediately.
Enforcement agents do not record the payment of a debt by a debit or credit card as this could lead to a risk that card details will be held longer than necessary.
How we handle data security concerns?
Marston has robust data security arrangements which are compliant with the ISO 27001:2013 standard on Information Security. Our compliance with this standard is regularly audited by an external audit firm.
BWV equipment is encrypted so that the images cannot be:
- viewed by anyone else but an agreed list of necessary users;
- accessed by unauthorised parties;
- destroyed by any party unless in line with the company policy; and
- shared by or with any party unless in line with the company policy.
Data is not readily accessible either on the camera or associated bonded equipment. In the event of seizure by authorities (or loss) data cannot be accessed without input from the Marston IT team.
Exercising your rights over the recording we have made of you
You have the legal right to ask for footage or any other personal information that we hold on you. All such requests should be made in writing to firstname.lastname@example.org.
We are obliged to provide you with this information within 40 days of receiving your request.
If you need any more independent information on your rights to access personal information held by organisations on you, you should refer to the website of the Information Commissioners Officer. Their link below includes suggested text that can be used when communicating with the organisation which holds personal data.
Use of footage
Marston administers all images recorded in line with all available guidelines and expectations in law.
We will only share images if one or more of the following circumstances occur:
- Consent has been gained from the customer at initial contact stage.
- There has been a criminal offence committed or alleged by one or more of the parties involved in an on-street visit.
- A complaint has been made and failure to provide evidence about a customer’s or enforcement agent’s behaviour could adversely affect the safety of another individual.
- The customer has made a complaint to our client, who has provided us with a copy of this complaint.
- A complaint has been made to stage 3 of the Marston complaint process, in which case evidence will be shared with the Marston Independent Advisory Group or the Civil Enforcement Association.