Closed consultation

Grid of amendments

Updated 25 August 2021

Paragraph	Amendment / deletion / addition	Rationale
Covering pages	References to particular parts of Protection of Freedoms Act (PoFA)	Updating Code is different paragraphs of PoFA from introducing it
Covering pages	Need to confirm contact	Different Home Office directorate
Covering pages	Contents	To reflect amended section headings
Throughout	Amended section headings and numberings	To simplify the layout
Throughout	Correction of typos / print errors and awkward grammar, very minor amendments, some paragraphs merged with those next to them or split into two or more eg paras 9-12	Easier for reader but not changing substance
Throughout	Legislation references updated	Reflects legislation that has been updated since first published.
Throughout	Removal of references to specific guidance / addition of general pointers to the sources of guidance	May already be out of date / could go out of date / not include new relevant guidance
Paragraph 1 - definitions	Legislation references re-ordered	In new chronological order.
Paragraph 1 - definitions	Definition of Commissioner plus footnote	To remove repetition throughout of the phrase “Surveillance Camera Commissioner”. Sets out brief description of the Commissioner’s role and the statutory footing. Negates the need for 1.7 and chapter 5.
Paragraph 3 - purpose	This whole paragraph is based on text in the original but moved eg from original para 2.1	Simplification
Paragraph 3 - purpose	Additional text: The overarching purpose of this code to enable operators of surveillance camera systems to make legitimate use of available technology in a way that the public would rightly expect and to a standard that maintains public trust and confidence.	To clarify the purpose of the Code (enabling).
Paragraphs 4 - 6 - purpose	Merges and replaces text in original 1.4 to 1.8 and draws on duplicate text elsewhere. Original 1.4-1.8 deleted.	Simplification
Paragraph 5 - purpose	Additional text: It is the way in which technology is used that is potentially intrusive rather than the technology itself.	To clarify the purpose of the Code (enabling).
Paragraph 9 - effect	Definition of “have regard to” added.	To clarify for the user and explains legal basis in the context of a code of practice.
Paragraph 12 - effect	Replaces old 1.12-1.15	Simplification and rebalancing detail. Original text refers to specific legislation that does not apply nationwide.
Original 1.18-1.20 - relevant documents	Deleted	May already be out of date / could go out of date / not include new relevant guidance
Paragraphs 15-17 - overview	Replacing the original text but based on it. Some original text has been moved to other sections before and after this and repetitions removed.	Simplification
Original 2.1-2.5 - overview	Deleted as text moved elsewhere / duplications removed	Simplification
Guiding principle 2	“Use” becomes “user”	We think this was a typo / print error.
Guiding principle 2	Text in this section was merged with comments about HRA / DPA from section 1. 2.1 was added into the re-draft.	Brings all references into one place and makes it easier for the user.
Paragraph 2.5	Additional text about bias	To reflect the Bridges v South Wales Police judgment
Paragraphs 3.1-3.2	Contains a small amount of new text	Clarification
Paragraph 5.1	New text about published policies	To reflect the Bridges v South Wales Police judgment
Paragraphs 8.1-8.3	Broadly the same text, with minor changes and slightly re-ordered.	Simplification
Paragraph 11.1	New text: it may be difficult to for an operator to argue that their purpose is to detect crime if the quality of the images produced is inadequate to support that purpose.	Clarification
Original 4.12.3 - principle 12	Deleted	Duplication
Paragraph 4.12	New text: LFR related	To reflect the Bridges v South Wales Police judgment
Original Chapter 5	Deleted	A lot of it replicates details in PoFA. There is a summary in a note accompanying paragraph 1.