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ANPR camera calibration records — SAR/FOI demand

ANPR systems must be maintained and calibrated to deliver reliable plate recognition and accurate timestamps. The Surveillance Camera Code of Practice (issued under Protection of Freedoms Act 2012 s.30) requires accurate, regularly-tested systems. The operator's BPA AOS or IPC Accredited Operator membership requires camera time synchronisation and audit. Demanding via SAR (UK GDPR Art 15) or, where the landowner is a public authority, FOI Act 2000, the calibration logs, NTP sync logs, last-service date, and audit trail will frequently expose deficiencies — out-of-sync clocks, unverified timestamps, or absent maintenance. Inability to evidence calibration undermines admissibility/weight under Civil Evidence Act 1995 s.9.

Legal basis

Protection of Freedoms Act 2012 s.30 (Surveillance Camera Code); Surveillance Camera Code of Practice 2013 (revised 2021/2022); UK GDPR Art 5(1)(d) accuracy; Civil Evidence Act 1995 s.9 (proof of business records); BPA AOS Code Section 21; IPC Code Section B12

How to identify this in your case

ANPR-based PCN; entry/exit timing pivotal to alleged contravention; site has multiple complaints / known time-drift issues.

Sample appeal wording

Dear [OPERATOR] — SAR + Evidential Disclosure Demand, Re: PCN [REF] — Vehicle [REG] Under UK GDPR Article 15 and as a precondition to your reliance on ANPR evidence under Civil Evidence Act 1995 s.9, I require the following: 1. The make, model and serial number of the ANPR cameras at [LOCATION]; 2. The most recent calibration and service certificates for those cameras prior to and following [DATE]; 3. The Network Time Protocol (NTP) source and synchronisation logs covering [DATE] +/- 7 days; 4. The maintenance log for the site covering 12 months either side of [DATE]; 5. The error/exception log for the cameras for [DATE]; 6. Records of any prior complaints relating to time accuracy or plate misreads at this site in the preceding 12 months; 7. Compliance audit under the Surveillance Camera Code of Practice (as revised 2021/22); 8. Evidence of compliance with BPA AOS Section 21 / IPC Section B12 audit requirements (as applicable). Without this evidence the ANPR records cannot be relied on as accurate (UK GDPR Art 5(1)(d)) and are not admissible as business records of sufficient weight under s.9 Civil Evidence Act 1995. The charge is denied pending full disclosure. Yours faithfully, [NAME]

Replace [PARKING DATE], [NtK DATE] etc. with your own dates before sending.

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Sources

  • PoFA 2012 s.30
  • Surveillance Camera Code 2013 (rev 2021)
  • Civil Evidence Act 1995 s.9
  • BPA AOS Code
  • IPC Code

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