The Act requires that Vuma Secure informs the subjects (the public) of the purpose for the cameras and that they may object or access the information about themselves. Do we do so?
Vuma Secure must take “reasonably practical steps” to inform members of the public of the information listed in section 18(1). Vuma Secure does put public notices on all active poles with indication on where to find processing, storage and data use information.
May the public object or access information about themselves?
A member of the public may request Vuma Secure to confirm whether it holds personal information about the data subject. (Section 23 of POPI) If Vuma Secure does, the data subject can also ask for a record of the personal information, and the identity of all third parties who have, or had, access to that personal information. These access to information rights will probably be interpreted to be subject to a reasonableness criterion. It would be absurd to require Vuma Secure to review all of its CCTV footage to determine whether it recorded a particular person at any point in time and we doubt that this court has been the intention of Parliament. But more tailored requests will have to be honoured.
The round mickey mouse ears are a public notice in this regard, and we will honour requests as required by law.