Purpose
Go Bus Transport Limited (“Go Bus”) endeavours to provide a safe and secure environment to protect its staff, customers and the interests of our stakeholders using our services. Closed Circuit Television (“CCTV”) cameras and systems (including visual and audio) are installed on most urban buses, SESTA vehicles and may also be present on any other company vehicle and at company depots and offices for the following purposes:
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To enhance staff and public safety,
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To enable monitoring and surveillance to improve security, monitor patronage and deter criminal activity on public transport and in general,
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To capture information that could be used to investigate crime, a health and safety situation and incidents involving Go Bus staff, contractors, customers and the general public, and
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To provide information to schools with respect to student’s behaviour on public transport.
This policy has been created to ensure that Go Bus, its employees and contractors (including public transport operators) comply with good practice and with the Privacy Act 2020 (the “Act”) with respect to the collection, use and disclosure of images captured by CCTV operating on public transport.
By operating or using any Go Bus service, you agree to the terms and conditions of this policy (as may be amended from time to time). This policy may be amended, withdrawn and replaced by publication on Go Bus’s website.
Scope
This policy applies to all employees of Go Bus, all Go Bus contractors and the general public who may enter the areas covered by the CCTV system operated by or on behalf of Go Bus.
Policy
1. Use of Data
Go Bus may disclose and use CCTV footage and other data collected from CCTV to the third parties below and for the purposes outlined above:
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NZ Police,
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Auckland Transport and other councils which Go Bus may be contracted to provide services to,
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The Ministry of Education, and
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Schools (for the purpose of addressing delinquent behaviour of school students).
2. CCTV Locations
CCTV on Go Bus vehicles is to be situated in locations which are clearly linked with the system’s specific purpose and recorded in the bus operator’s register of CCTV systems.
CCTV at company depots and offices will similarly be situated in locations which are clearly linked with the system’s specific purpose and recorded in the bus operator’s register of CCTV systems.
3. Monitoring
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The recording devices/servers for CCTV systems are to be installed in secure locations as agreed upon by Go Bus’s nominated CCTV Administrator. Only persons trained and authorised as CCTV Operators are allowed access to recorded CCTV footage stored in these locations.
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All footage is kept for the duration of the intended purpose as determined by Go Bus from time to time, and in any event no longer than 30 days. This period reflects standard industry practice and is consistent with our contractual responsibilities to council and other customers. After that time, the data is overwritten as part of the recording process, unless it is exported for evidential purposes as may be required.
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Live streaming system monitoring may be carried out from time to time to assist with crime detection, deterrence and prevention, and to monitor potential health and safety hazards to Go Bus employees, contractors or members of the public.
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Go Bus reserves the right to have remote access to all footage created by the CCTV systems.
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Where systems are monitored via a mobile device (such as a smartphone, tablet or laptop) a CCTV Operator shall ensure that no unauthorised person has the ability to view the device.
4. Control and operation of systems
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Unless Go Bus agrees otherwise, CCTV systems will be installed on vehicles owned or operated by Go Bus or contracted by Go Bus to third-party contractors and at its depots and offices.
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The CCTV systems will operate for the full duration of the time that the vehicle is in use and 24/7 for depots and offices.
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All areas of our vehicles will at some point in time be monitored by the CCTV system, the exceptions being listed below:
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CCTV coverage will not be directed at private property except unavoidably as part of a wide angle or long shot while panning past.
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Audio will only be recorded from the driver compartments (to ensure recordings of the driver and passenger interactions).
5. User access
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Go Bus will ensure its employees or contractors who install, operate and monitor CCTV systems receive appropriate training in the technical, legal and ethical parameters of appropriate camera, audio and data use and understand their responsibilities under the Act.
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The roles and responsibilities are outlined below:
CCTV Administrator |
Full System Access to all CCTV system features and programming |
Go Bus appointed representative |
CCTV Operator |
Access to all CCTV systems including some programming ability, live view, playback and export or full system access for maintenance purposes. |
Go Bus appointed representative |
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The CCTV Administrator is responsible for:
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Undertaking an annual review of the use of all CCTV systems, and
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Referring all public or Police requests for footage to a Go Bus Privacy Officer and the CCTV Operator.
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CCTV Operators are responsible for:
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Ensuring that CCTV equipment is installed on relevant bus services, depots and offices,
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Organising the training and authorising of staff of the public transport operator in relation to this policy,
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Ensuring the on-going maintenance and accuracy of the CCTV system,
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Ensuring that footage, audio or other data from the CCTV system requested by the CCTV Administrator or the Police is provided within 24 hours of the receipt of the request and the data released is recorded in the CCTV Access Log,
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The establishment, oversight and maintenance of a record of all released or viewed CCTV footage, audio or data,
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Referring all other requests for data from the CCTV system to the CCTV Administrator,
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Maintaining security of the CCTV system, the monitors and footage (tapes, drives, disks etc),
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Maintaining the CCTV Access Log,
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Ensuring signage is in place on all bus services and in accordance with this policy,
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Organising training of the bus operator’s employees and contractors in relation to the CCTV system, this policy and the Act,
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Ensuring the bus operator complies with the Act and this policy in relation to the CCTV system,
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Dealing with any requests for access or correction of data by individuals in accordance with this policy and the Act, and
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Maintaining confidentiality in regard to CCTV data, duties and observations and ensuring that all employees and contractors maintain such confidentiality.
6. Use of information collected
In accordance with the Act, and with regard to the listed exceptions in the Act, information collected by the CCTV systems will only be used for the purpose for which it was collected.
7. CCTV information access and the Police
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The NZ Police may access footage on short notice from those CCTV systems that have been set up for purposes linked with crime detection and prevention.
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All footage released to the Police at the request of the Police, or when criminal activity is suspected, will be recorded in the CCTV Access Log and filed with the Go Bus Privacy Officer.
8. CCTV information access by individuals
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Unless there are good reasons to refuse access in accordance with the Act, members of the public have the right to request access to, and correction of, any personal information held by the CCTV system.
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A request by the public to view footage that contains information relating to other individuals must be in writing and will be a dealt with as either:
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a matter to be referred to the Police, or
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a LGOIMA request under the Local Government Official Information and Meetings Act 1987 (where related to council or central government funded services), or
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where the footage requested for viewing only shows the individual who has made the request, the request will be dealt with in accordance with the Act.
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Any request to view footage will be limited by the need to protect other persons’ privacy. If a request to view the footage is unable to be granted without unreasonably breaching others’ privacy, a written description may be provided by the CCTV Operator of what they are doing in the footage. Any such requests will be responded to within 20 working days by the CCTV Operator and are subject to review by a Go Bus Privacy Officer as per Go Bus’s policies and procedures.
9. CCTV and Operator staff
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Go Bus will investigate any suspected breach of the use of the CCTV system by the bus operator’s employees or contractors.
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Any staff incidents or misconduct detected by the CCTV system will be handled in accordance with the contract between Go Bus and the authority which it provides contracted services to
10. CCTV Signage
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Individual systems and/or camera areas will be clearly signposted to notify the public.
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Signs will clearly display the message “CCTV and Audio recording in operation” or a similar message and be of a size and style that makes them readily visible to people entering the area. Where it is impractical to include all the information, the sign will direct the public to the Go Bus website where this policy can be viewed.
11. Who can you contact for further information
If you have any queries about this policy or any aspect of the operation of CCTV cameras by Go Bus, please contact our Privacy Officer by email at privacy@gobus.co.nz or at Go-Bus Transport Limited, Level 2, 678 Victoria Street, Hamilton 3204.
More information about your rights and our obligations in respect to privacy and information on making a privacy complaint are available from the Office of the Privacy Commissioner at www.privacy.org.nz or PO Box 10 094, The Terrace, Wellington 6143.
Policy Review
This policy will reviewed be annually.
Last updated: July 2021.