Privacy Information Notice - GoodSAM
GoodSAM is a 3rd party cloud-based supplier of services to West Yorkshire Police.
Data obtained via the GoodSAM platform is done so by utilising a third-parties device. Before the use of this device is initiated consent will be obtained from the user. It is understood that:
- the individual who provides that access to their device and thus data (potentially comprising location, video and audio) may not obtain additional consent of third parties in their presence, and
- the use of the platform can be in response to an emergency situation, and the end user may not have time, or presence of mind, to consider the full implications of data provided
All data collected and retained is done so for a policing purpose:
- protecting life and property
- preserving order
- preventing the commission of offences
- bringing offenders to justice
- any duty or responsibility arising from common or statute law.
West Yorkshire Police have completed a Data Protection Impact Assessment paying due regard to the above legislation as well as the Surveillance Camera Code of Practice and the Collage of Policing Approved Professional Practice.
All data obtained via GoodSAM is subject to an initial review period of 90 days in line with West Yorkshire Police’s Information Management Policy and Force Retention Schedule.
On review, files and footage will only be retained further if it is necessary and proportionate for the purpose or purposes for which it was obtained. Where material is evidential or potentially evidential, this will be in line with government guidelines set out in the Home Office (2005) Code of Practice on Management of Police Information.
GoodSAM use Amazon Web Services (Public Sector Servers) to host their platform and store all recorded data. Amazon are accredited to national and international security standards which are detailed at https://aws.amazon.com/
Location data is obtained via Global Positioning Satellite (GPS) services when enabled on the end user’s device.
Location data is retained for 2 years as part of the record of contact, at which time it will be weeded from the system unless extended retention is necessary and proportionate for the purpose or purposes for which it was obtained.
All footage that is recorded is held within the GoodSAM platform and is owned and managed by West Yorkshire Police.
West Yorkshire Police consider use of livestreaming an extension of a 999 call when used with members of the public in response to an emergency. Footage will be used to assist in the understanding of what is being reported, enable appropriate response to, and resourcing of, the incident as presented.
Where livestreaming is used in response to an ongoing incident, it falls outside intrusive or directed surveillance as defined in Part II of the Regulatory Investigatory Powers Act 2000. As such a directed or intrusive surveillance authority will not be required.
Use of the GoodSAM in this regard will be to facilitate communications between West Yorkshire Police, members of the public, external businesses, and partners.
Video Consultation calls may or may not be recorded depending on the specific circumstances of the contact. Calls will only ever be recorded where there is a defined policing purpose. There is a duty on the officer/staff member initiating the call to ensure all other parties present on that call are aware if the call is being recorded.
Data on an individual’s device remains the property of the individual, where copies are uploaded, West Yorkshire Police reserve the right to retain these where a clear policing purpose exists, and in line with the Home Office (2005) Code of Practice on Management of Police Information.
Use of the GoodSAM service will require a telephone number or email address. Usually these will be obtained with consent of the end user, often at the point of contact.
There may be occasions where such details are provided by a third party to assist in achieving a legitimate policing purpose. An example of this could be to assist in the location of a person whom they believe to be at risk.
Through the use of GoodSAM the end user’s IP Address may also be obtained and recorded.
This data is retained for management and accountability purposes and is necessary to maintain a record of contact. 2 years as part of the record of contact, at which time it will be weeded from the system unless extended retention is necessary and proportionate for the purpose or purposes for which it was obtained.
GoodSAM does not generate persistent cookies which hold user data or preferences. The only cookies created on the user device are essential session cookies which expire after the session ends.
Since these cookies are for the sole purpose of carrying out or facilitating the transmission of a communication over an electronic communications network, there is no requirement for prior consent to be obtained in accordance with Privacy and Electronic Communications Regulations 2003.
Under General Data Protection Regulations, the use of data and cookies are permitted as the consent is considered to be given when the user dials the emergency services.
Under the E-privacy Directive 2009, no consent is required for the legitimate use of data/cookies for providing care and assistance in potentially life-threatening emergencies such as calls to the 999 service.
Page last reviewed December 2021.