Automatic Number Plate Recognition (ANPR) Policy
1. Statement of Policy
Governance and Standards
The National Police Chiefs’ Council (NPCC) Automatic Number Plate Recognition (ANPR) Portfolio forms part of the Intelligence Portfolio within the NPCC Crime Business Area. The NPCC ANPR Portfolio is led by a Chief Constable who has delegated authority from Chiefs’ Council for the management of all national ANPR business within policing. The NPCC ANPR Lead is supported by the NPCC Strategic Capability Manager, who manages the national ANPR portfolio on their behalf.
The ANPR Capability Leadership Group (ACLeG) is a national strategic group chaired by the NPCC ANPR Lead and operates as a senior reference group for the development of strategic ANPR capabilities, including technical infrastructure and systems. The ACLeG provide police led strategic oversight of the delivery of the National ANPR Capability Framework.
The national ANPR Capability Optimisation Group (ACOG) reports to the ACLeG and provides multi-agency oversight at the operational level of national ANPR capability, supported by working groups, comprised of ANPR subject matter experts (SMEs), Regional Chairs and LEA representative members represent their force or region.
The Welsh Regional ANPR Capability Group (WRCG) reports to ACOG and brings together the four Welsh forces (Dyfed-Powys Police, North Wales Police, Gwent Police and South Wales Police) and partner agencies to coordinate the delivery of the National ANPR Strategy (2020-2024) and the National ANPR Service (NAS) project to support the National ANPR capability in protecting the public, reducing crime and bring offenders to justice.
The strategic management of Dyfed-Powys Police (DPP) ANPR capability is determined by the DPP ANPR Strategy Group, which is chaired by the Director of Intelligence, who is the force strategic lead. Representation on the group includes ANPR Specialists, Specialist Operations Department, Force Intelligence Bureau, Force Intelligence Analyst(s) Information, ICT and the Finance Department. The Group set the strategic and tactical objectives, confirm that development proposals are appropriate and proportionate, commensurate with the development of national and regional strategic policy. The group report to the DPP Finance and Strategy Board.
Within Dyfed-Powys Police, the Assistant Chief Constable is the Chief Officer lead and has overall responsibility within the Force for the provision of ANPR. This includes the provision of system monitoring including National ANPR Standards for Policing and Law Enforcement (NASPLE) compliance and ensuring staff members are appropriately trained according to their needs.
NASPLE describe the required standards for the development and use of ANPR systems by law enforcement agencies (LEAs). The Dyfed-Powys Police policy for the development of ANPR is consistent with NASPLE. The use of ANPR within Dyfed-Powys Police is detailed within the ANPR Procedures document.
Infrastructure development is in accordance with NASPLE and all proposals for new infrastructure are submitted to the Force ANPR Strategy Group who take the strategic assessment and privacy impact assessment into account and balance the protection of the public with the rights and legitimate expectations of individual privacy. Approval from this group is required before any development is progressed to the Finance and Strategy Board who make the final decision.
The Force ANPR Strategy Group ensure that arrangements are in place for the review of all Number Plate Reading Device (NRD) locations submitting data to the ANPR system. Review is undertaken annually at a minimum to ensure the deployment remains appropriate and proportionate.
Vehicle mounted ANPR systems will be deployed in accordance with NASPLE standards for deployment of ‘Vehicle - Mounted Systems’.
ANPR Deployment in support of operational response following the report of a crime or incident is made on authority of the Force Control Room Inspector/Supervisor and a record of that authority will be made within the incident log.
Local Policing Area (LPA) Commanders ensure that the use of ANPR is embedded into force strategic and tactical processes.
The overall purpose of this policy is to realise the benefits of the use of ANPR relative to:
- Support of a national Counter Terrorist operation or initiative.
- Support of a local Counter Terrorist operation or initiative.
- Support of the protection of vulnerable persons.
- Support of the investigation of serious crime.
- Support of a roads policing initiatives.
- The prevention and detection of crime.
- Gathering of evidence and intelligence.
- Control strategy areas.
Applies (but not limited) to: All categories of Dyfed-Powys Police Officers and Staff, whether full-time, part-time, permanent, fixed term, temporary (including agency staff, associates and contractors), seconded staff and volunteers. All officers, staff and volunteers accessing and using Force assets and property must have due regard to the contents of this policy.
2. Policy Scope
The Police National Computer (PNC) is the primary database to support operational response. Whenever possible the ‘live’ PNC link will be used. The PNC extract file is provided three times every 24 hours; the ANPR Specialist will ensure that it is loaded onto the ANPR system upon receipt.
Within the PNC files, the ACTion (ACT) report is the primary database. This database is used for the circulation of any vehicle of interest that meets the criteria within the PNC business rules. This is monitored 24 hours a day, 7 days a week within the Dyfed-Powys Police Force Control Room and resources deployed as appropriate. ACT reports are designated as high, medium, and low priority.
The member of staff who creates a list of VOI will ensure that the information within it is accurate, of current relevance and in the format prescribed within NASPLE.
The ANPR Specialist will monitor the creation, use and maintenance of local lists of VOI for operational response purposes, reporting concerns to the Strategic Lead as appropriate.
The Strategic Lead will ensure that arrangements are in place, to monitor the creation, use and maintenance of a list of VOI for intelligence monitoring purposes.
Performance Evaluation
The ANPR Manager is responsible for monitoring the performance of all components of the ANPR Infrastructure. The performance of a Number Plate Reader Device (NRD) will be assessed on installation and thereafter at least annually for all NRD that provide supporting imagery and every 6 months for those that do not provide images in accordance with NASPLE Part 2 Para 12.
Data Access
The Strategic Lead and the ANPR Manager are accountable for the authorisation of staff access ANPR data. The Strategic Lead ensures that a record of authorised staff is maintained and reviewed, access amended or access cancelled on a change of role as appropriate. The level of access granted must always be proportionate to their role.
Once access is granted staff will be advised on their access level and provided with the latest ANPR Guidance & Use document, which informs users that they are required to provide sufficient information to justify all ANPR searches and that ANPR system access can only be made for a policing purpose. Users are aware that they asked to justify their use of the system at any time in the future.
Staff accessing ANPR data must ensure that the access is appropriate in each case taking account of NASPLE. Authorisation for searches must always be considered and properly authorised when required. Any ANPR search for data over 90 days must be requested on the ANPR Data Search Form and authorised in writing by an officer of Inspector Rank (or above). A copy of the written request and authorisation will be filed and retained in accordance with MOPI guidelines. Staff with +90 day ANPR access will be limited and reviewed on a regular basis. An audit of +90 day searches will be completed on a regular basis.
Staff authorising access to ANPR data must always ensure that access is proportionate and in the interest of justice in each case taking account of Data Protection legislation and NASPLE data access provisions.
Evidential Use and Disclosure of Data
ANPR data is used for law enforcement purposes of the prevention, detection or
prosecution of criminal offences and has a significant part to play in bringing offenders
to justice. The disclosure of ANPR data will be in accordance with NPCC national guidance.
Auditing & Quality Assurance
The Strategic Lead will ensure that a record of access to ANPR data by their staff, including the reason for that access and details of any authorisation of that access where required is maintained. Regular audit of access to ANPR data will take place, and a record of all audit activity undertaken will be kept. The Strategic Lead will ensure compliance with the National Standards for Compliance and Audit of Law Enforcement ANPR.
Where data has been accessed for which the Data Controller is from another LEA, the Data will be provided to that Data Controller on request, subject to the appropriate conditions being met.
Details of audits undertaken will be made available to the Information Commissioner, the Surveillance Camera Commissioner, and the Home Office on request.
For internal requests for searches on captured data that have been on the system for more than 90 days, an ANPR Data Request form must be completed and submitted to the Force Intelligence Bureau.
3. Powers and Policy/Legal Requirements
Procurement
Procurement of new ANPR equipment is the responsibility of the force ANPR Manager. Suppliers of new equipment must be able to satisfy the Force that any ANPR equipment supplied is compliant with the current NASPLE version. Acceptance of such equipment will be subject to evaluation and sign off by the ANPR manager. Existing and new equipment will be subject to an annual evaluation conducted by the ANPR Manager to ensure continued compliance with NASPLE performance requirements.
Oversight of equipment purchases, changes, upgrades and associated costs will be the responsibility of the Force ANPR Strategy Group, with the tactical and strategic use of ANPR also the subject of regular review by the Group.
System Security
Access to the Back Office facility (BOF) is strictly limited to trained and authorised staff in accordance with the current requirements of NASPLE. Operator permissions are granted according to role and function, which is also controlled by BOF Administrators. The ANPR manager is required to audit BOF user access on a monthly basis. The Force IT Department also have the ability to grant remote BOF access to known and suitably vetted engineers as each need arises. Open and unrestricted remote access to BOF is not permitted.
Data Protection, Storage, Retention and Use
The Force is committed to ensuring that all ANPR Read & Hit Data is stored and retained within the BOF, in accordance with the minimum standards set by the current version of NASPLE. The storage, retention, and use of all such data will be consistent with the requirements of the Criminal Procedure and Investigation Act 1996, Data Protection Act 2018, Human Rights Act 1998, and Guidance of the Management of Police Information.
In line with NAAS, ANPR data will be retained as live information for the periods below: -
- Reads ACPO Recommended Text Data - 1 year
- Plate patch image - 1 year
- Overview image - 6 months
- Hits Force Requirement Text Data - 1 year (NAAS guidance)
- Plate patch image - 1 year (NAAS guidance)
- Overview image - 6 months
Dyfed-Powys Police does not currently share its ANPR data outside of the Police Service unless they are a LEA authorised to access the national ANPR Service. All other access would be subject to an Information Sharing Agreement, a lawful basis under Data Protection legislation, or under other legislation where lawfully required to do so.
Related Policies, Protocols, Practices or Service Agreements
This policy follows the standards set in the National ANPR Standards for Policing and Law Enforcement (NASPLE). This document (July 2022 – V.24) has been embedded here.
4. Options and Contingencies
The ANPR Manager, with the support of the finance team, will maintain an Asset Register of all live ANPR camera installations. This register shall describe:
- Location of the asset
- Make or model
- Date of purchase
- Purchase price and
- Any other details or notes pertinent to its performance or service.
Periodically the register shall be reconciled with the Force’s Fixed Asset Register maintained by the Finance team. Differences shall be investigated and resolved without undue delay.
Additions & Substitutions
Replacement assets shall be purchased in accordance with force’s procurement policy and practices. The ANPR manager, with the support of the finance team, shall update the Asset Register so the record reflects current equipment and its location.
Disposals
The ANPR manager, with the support of the Finance team, shall update the Asset Register for the removal and disposal of assets. Physical disposal shall be conducted with the force’s practices for the controlled disposal of assets. The ANPR Specialist shall notify the Finance team without undue delay of the disposal of assets recognising that where assets retain a book value at the time of disposal, this will form a charge to in-year revenue budgets. Disposals shall be authorised at the Strategic ANPR Group as far as practicable possible in advance of action to dispose.
New Infrastructure Sites
The ANPR Manager, with the support of the Finance team, shall update the Asset Register for the creation of new infrastructure sites. Assets located at the new sites are treated as Additions & Substitutions as above.
Relevant parties of this policy are detailed below:-
- Director of Intelligence
- Detective Chief Inspector – FIB
- Head of Intelligence Analysis
- Intelligence Analyst
- Intelligence Manager
- Intelligence Officer
- Intelligence Researcher
- Intelligence Support Officer
- Any member of staff with ANPR system access or requesting data from the system.
This policy complies with the Code of Ethics 2024 principles –
- Courage
- Respect and Empathy
- Public Service
5. Take action and review
The review and any revisions will take account of:
- The policy’s effectiveness, as assessed by the Force Executive Board and internal/external audit
- Any changes to legislation/Home Office Guidance
- Challenges to the policy and
- Any identified inefficiencies in relation to implementation.
The review of the contents of this policy is the responsibility of the Director of Intelligence. Review of the policy will be undertaken annually.
All enquiries relating to this policy should be directed to Director of Intelligence.
CODE OF ETHICS CERTIFICATE OF COMPLIANCE
This policy has been drafted in accordance with the Code of Ethics and has been reviewed on the basis of its content and the supporting evidence and it is deemed compliant with that Code and the principles underpinning it.
HUMAN RIGHTS ACT CERTIFICATE OF COMPLIANCE
This policy has been drafted in accordance with the Human Rights Act and has been reviewed on the basis of its content and the supporting evidence and it is deemed compliant with that Act and the principles underpinning it.
EQUALITY IMPACT ASSESSMENT
Section 4 of the Equality Act 2010 sets out the protected characteristics that qualify for protection under the Act as follows: Age; Disability; Gender Reassignment; Marriage and Civil Partnership; Pregnancy and Maternity; Race; Religion or Belief; Sex; Sexual Orientation.
The public sector equality duty places a proactive legal requirement on public bodies to have regard, in the exercise of their functions, to the need to:
- eliminate discrimination, harassment, victimisation, and any other conduct that is unlawful under the Act;
- advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it;
- foster good relations between persons who share a relevant protected characteristic and persons who do not share it.
The equality duty applies to all protected characteristics with the exception of Marriage and Civil Partnership, to which only the duty to have regard to the need to eliminate discrimination applies.
Carrying out an equality impact assessment involves systematically assessing the likely or actual effects of policies on people in respect of all the protected characteristics set out above. An equality impact assessment should be carried out on any policy that is relevant to the public sector equality duty.
EQUALITY IMPACT ASSESSMENT COMPLETED: February 2024