Public Realm Patrols, Body Worn Video & Incident Reporting

1. Introduction

My Local Bobby Ltd (MLB) provides visible public realm, community safety and security patrol services. In carrying out these services, our officers may encounter members of the public and may collect or create personal information as part of body worn video (BWV), incident reporting, safeguarding activity, crime prevention, evidence gathering and operational liaison.

This Privacy Notice explains how MLB processes personal information relating to members of the public and other individuals encountered during operational activity. It is intended to supplement MLB PD 06 – Privacy Notice: General Users & Clients.

My Local Bobby Ltd is registered with the Information Commissioner’s Office under registration number ZA241437. Questions about this notice or the way MLB handles personal data can be directed to Luke@mylocalbobby.co.uk.

2. Who This Notice Applies To

This notice may apply to you if you are encountered, observed, assisted, spoken to, reported, identified or incidentally captured during an MLB public realm patrol or related operational activity. This can include:

• members of the public and passers-by;
• victims, witnesses, complainants and persons reporting concerns;
• persons involved in, suspected of, or affected by an incident;
• children, young people and vulnerable adults where safeguarding concerns arise;
• business owners, employees, visitors and contractors encountered operationally;
• individuals captured incidentally in BWV footage or other authorised operational imagery.

3. Personal Information We May Capture

4. Why We Process This Information

MLB processes operational personal information only where there is an identified and legitimate operational purpose. Depending on the circumstances, these purposes may include:

• protecting the safety and security of members of the public, businesses, our officers and partner personnel;
• preventing, detecting and responding to crime, anti-social behaviour and other incidents;
• creating an accurate contemporaneous record of incidents, officer actions and interactions;
• providing evidence and supporting lawful investigations, complaints, legal proceedings or regulatory enquiries;
• supporting safeguarding activity and referrals concerning children or vulnerable adults;
• sharing relevant information with the Police, local authorities or other appropriate bodies where lawful and necessary;
• monitoring and demonstrating service delivery, quality, accountability and officer conduct;
• responding to requests, complaints or claims relating to an incident or interaction.

5. Lawful Basis

The lawful basis relied upon will depend on the circumstances and the nature of the information being processed. MLB will process personal data only where a lawful basis is available under UK data protection law.

For public realm and operational activity, this may include processing that is necessary for MLB’s legitimate interests and those of its clients or third parties, including public safety, crime prevention, security, service accountability, protection of legal rights and the proper investigation of incidents. Processing may also be necessary to comply with a legal obligation.

Where special category personal data or criminal offence data is processed, MLB will ensure that an additional lawful condition or appropriate legal basis applies. Safeguarding and emergency situations will be handled in accordance with the applicable legal framework and MLB safeguarding procedures.

MLB does not rely on consent as the routine lawful basis for operational BWV or incident reporting, as withdrawing consent would generally be incompatible with the purposes for which an incident record or evidential recording is required.

6. Body Worn Video (BWV)

MLB officers may wear body worn video equipment as part of their operational duties. BWV is used to support safety, accountability, accurate incident recording and, where appropriate, evidential purposes.

• BWV is not intended to be used indiscriminately. Recording decisions are made in accordance with MLB’s operational procedures and the circumstances facing the officer.
• Where appropriate and practicable during a direct interaction, officers will make individuals aware that BWV is recording. The equipment/uniform arrangements also provide a visible indication that BWV may be in use.
• During fast-moving, confrontational, emergency or evidential situations it may not always be practical to provide an individual privacy explanation before recording begins.
• People who are merely passing through a public place may be captured incidentally. Such incidental capture does not mean that the person is suspected of wrongdoing.
• Operational BWV is not treated as publicity material. It must not be posted on social media or supplied externally for publicity by operational staff.
• Access, review, disclosure, download and retention of BWV are controlled and limited to legitimate operational, legal, safeguarding, investigative or contractual purposes.

6.1 BWV Storage, Retention, Recovery & Deletion

Once captured, BWV footage is transferred to and retained within MLB’s authorised BWV storage arrangements. Access is restricted to authorised personnel with a legitimate operational, safeguarding, evidential, complaint, legal or data protection purpose. Footage is not routinely downloaded, copied or retained outside the approved system.

Following the standard 30-day retention period, footage may remain technically recoverable through the authorised system for up to three months from the date of recording. This recovery capability is not treated as an extension of routine operational retention or routine user access. Recovery will only be undertaken where there is a legitimate and authorised reason to do so, for example a Police investigation, safeguarding matter, complaint, legal claim, data subject request or other lawful requirement.

After the applicable recovery window has expired, footage that has not been separately preserved for an authorised purpose will no longer be recoverable through the normal system arrangements.

Where footage is identified within the retention or recovery period as relevant to an incident, Police investigation, safeguarding concern, complaint, legal claim, regulatory enquiry or other continuing lawful purpose, the relevant recording may be preserved beyond the routine period for as long as is necessary for that specific purpose.

Where BWV is downloaded or extracted for an authorised purpose, the extracted copy becomes a controlled record in its own right. It must be securely handled, access-restricted and retained only for as long as required for the purpose for which it was extracted. It must not be stored on personal devices, personal email accounts or unauthorised storage locations.

Requests for footage should be made as promptly as possible and should include sufficient information to identify the relevant recording, such as the date, approximate time, location and nature of the interaction. Where a valid request is received before routine deletion or expiry of the recovery window, MLB will take reasonable steps to preserve relevant footage while the request is considered.

7. Incident Reporting & TrackTik

MLB uses TrackTik as an operational reporting system. Officers may create incident and activity reports containing personal information where this is necessary to record what occurred, what action was taken and what follow-up is required.

Reports should be factual, relevant and proportionate. Officers are expected to avoid unnecessary personal information, opinion or speculation. Where an individual provides personal information directly, officers should explain the purpose of collection where appropriate and practicable and can direct the individual to this Privacy Notice for further information.

Operational records may be reviewed by authorised MLB management and other authorised personnel for incident management, quality assurance, intelligence analysis, safeguarding, contract reporting and lawful information sharing.

8. How We Tell People Their Information Is Being Processed

MLB uses a layered approach to privacy information because public realm operations do not always allow a full written privacy notice to be provided at the point information is captured.

9. Who We May Share Information With

Personal information is not shared simply because it is available. Where necessary, lawful and proportionate, operational information may be shared with:

• the local authority or client commissioning the relevant service, subject to the applicable contractual and data protection arrangements;
• Police and other law enforcement bodies;
• local authority safeguarding services or other statutory safeguarding partners;
• emergency services;
• courts, regulators, legal advisers, insurers or other bodies where disclosure is required or appropriate for legal claims, investigations or regulatory purposes;
• authorised service providers supporting MLB’s secure operational systems, subject to appropriate data protection arrangements.

Before disclosure, MLB will consider the purpose, necessity, proportionality and sensitivity of the information. Where appropriate, reports supplied for general performance purposes will be minimised, aggregated or anonymised rather than routinely disclosing identifiable personal information.

10. Information Security & Access

MLB is committed to protecting operational personal information from unauthorised access, alteration, disclosure or loss. Appropriate physical, electronic and managerial controls are used to safeguard information.

• Access to operational systems and records is limited to authorised users according to role and operational need.
• Personal information must not be copied into personal email accounts, personal devices or unauthorised messaging services.
• BWV and incident records must only be downloaded or shared for an authorised purpose.
• Sensitive safeguarding, evidential and personal information is handled on a need-to-know basis.
• Suspected personal data breaches are escalated through MLB’s data protection and management processes.

11. Retention

MLB will not retain personal information for longer than is necessary for the purpose for which it was collected, subject to legal, regulatory, contractual, evidential, safeguarding and investigative requirements.

Routine BWV footage is retained for 30 days. Following that period, footage may remain technically recoverable through MLB’s authorised BWV system for up to three months from the date of recording. Recovery is restricted to legitimate and authorised purposes and is not used as routine operational storage.

Where footage or an incident record is required for an ongoing Police investigation, safeguarding matter, complaint, legal claim, regulatory enquiry, data protection request or other lawful purpose, it may be preserved beyond the routine period for as long as necessary for that specific purpose.

Other operational records, including TrackTik incident reports, may be subject to different retention periods according to their purpose and applicable legal, contractual or operational requirements.

Where a client contract imposes specific requirements concerning the return, deletion or continued lawful retention of client personal data, MLB will apply those requirements alongside UK data protection law.

12. Your Data Protection Rights

Depending on the circumstances and the lawful basis for processing, individuals may have rights including the right to request access to personal data held about them, request correction of inaccurate information, object to certain processing, request restriction of processing or request erasure.

These rights are not absolute. For example, MLB may be unable to disclose or erase information where doing so would prejudice the rights of another person, an investigation, safeguarding activity, crime prevention, legal proceedings or another lawful purpose.

A request concerning BWV should be made as promptly as possible and provide sufficient information to help locate the relevant footage, such as the approximate date, time, location and nature of the interaction.

Routine footage is retained for 30 days and may remain technically recoverable for up to three months from the date of recording. MLB may need to verify the requester’s identity before releasing personal information, and third-party information may need to be redacted. Where relevant footage can still be located or recovered and a valid request requires preservation, MLB will take reasonable steps to secure it while the request is considered.

13. Children & Vulnerable People

Operational activity may involve children, young people or vulnerable adults. MLB recognises that information relating to these individuals can be particularly sensitive. Officers and management will apply MLB safeguarding procedures alongside data protection requirements, limiting information to what is necessary for protection, referral, recording and appropriate follow-up.

Where a safeguarding concern requires information to be shared to protect an individual from harm, information may be provided to the appropriate statutory or emergency service where there is a lawful basis to do so.

14. Complaints & Contact

If you have questions about this Privacy Notice, believe MLB holds personal information about you, wish to make a data protection request, or have concerns about the way your personal information has been handled, please contact:

If you are not satisfied with MLB’s response to a data protection concern, you have the right to raise the matter with the Information Commissioner’s Office.

15. Relationship With Other MLB Policies

This operational Privacy Notice should be read alongside MLB PD 06 – Privacy Notice: General Users & Clients and relevant MLB policies and procedures governing body worn video, data protection/information handling, safeguarding, incident reporting, complaints and operational conduct.

Where a specific client or service has additional information-sharing or data-controller arrangements, those requirements will be applied in conjunction with this notice.