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[2012] VCAT 1472
Victorian Civil and Administrative Tribunal
2012-09-27
Original judgment source is linked above.
Information privacy- complaint - whether retention of images taken at a protest is an interference with privacy - information privacy principle 4.2- meaning of "needed for any purpose"- whether interpretation compatible with human rights to privacy, to freedom of expression and to peaceful assembly - whether disposal or alteration of documents permitted by public records requirements - whether retention unlawful under the Charter of Human Rights and Responsibilities - Information Privacy Act 2006 ss 6, 14,29, 39 - Charter of Human Rights and Responsibilities Act 2006 ss 7(2),13,15,16,, - ,
Caripis v Victoria Police (Health and Privacy) [2012] VCAT 1472
The Information Privacy Act, the Charter of Human Rights and Responsibilities Act and the Public Records Act
"4.2 An organisation must take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for any purpose."
"(1) If a provision made by or under this Act is inconsistent with a provision made by or under any other Act that other provision prevails and the provision made by or under this Act is (to the extent of the inconsistency) of no force or effect".
"(1) So far as it is possible to do so consistently with their purpose, all statutory provisions must be interpreted in a way that is compatible with human rights.
(2) International law and the judgments of domestic, foreign and international courts and tribunals relevant to a human right may be considered in interpreting a statutory provision."
(a) not to have his or her privacy, family, home or correspondence unlawfully or arbitrarily interfered with;
(2) Every person has the right to freedom of expression which includes the freedom to seek, receive and impart information and ideas of all kinds,..
16. (1) Every person has the right of peaceful assembly.
(2) Every person has the right to freedom of association with others..."
" (1) This Part sets out the human rights that Parliament specifically seeks to protect and promote.
(2) A human right may be subject under law only to such reasonable limits as can be demonstrably justified in a free and democratic society based on human dignity, equality and freedom, and taking into account all relevant factors including -
(b) the importance of the purpose of the limitation; and
(d) the relationship between the limitation and its purpose; and
(e) any less restrictive means reasonably available to achieve the purpose that the limitation seeks to achieve.
(3) Nothing in this Charter gives a person, entity or public authority a right to limit (to a greater extent than is provided for in this Charter) or destroy the human rights of any person."
"Footage of this kind can be useful in identifying protesters who engage in unlawful activity at other protests. It can also assist police to understand the organisation of a protest and the tactics used by the group and by individual protesters. This kind of intelligence is also used in the risk management process by assisting police and other agencies to assess the threat level of the event and other similar events".
"20 The operation of ss 32(1) and 7(2) was recently considered by the High Court in Momcilovic v R. So far as s 32(1) was concerned, French CJ, Crennan and Kiefel JJ and Gummow J, Hayne J and Bell J each held in separate judgments that s 32(1) does not require or authorise a court to depart from the ordinary meaning of a statutory provision, or the intention of Parliament in enacting the provision, but in effect requires the court to discern the purpose of the provision in question in accordance with the ordinary techniques of statutory construction essayed in Project Blue Sky Inc v Australian Broadcasting Authority.
21 Their Honours did not achieve the same degree of consensus as to the effect of s 7(2). The Court of Appeal in Momcilovic held that the interpretative task under s 32 does not involve the application of s 7(2), which needs to be considered only for the purposes of making a declaration of inconsistent interpretation under s 36. In the High Court, French CJ, Crennan and Kiefel JJ concluded that s 7(2) 'cannot inform the interpretative process which s 32(1) mandates' but is engaged only when and if 'the statutory provision under consideration imposes a limit on its enjoyment'. '[I]t cannot be interpreted into the content of the rights and freedoms set out in the Charter'. In contrast, Gummow, Hayne and Bell JJ held that s 7(2) does inform the interpretative task to the extent that it will usually be appropriate for a court first to consider whether under s 7(2) there is scope for a justified limitation of the right in issue. It followed, as Gummow J put it, that '[s]ection 32(1) is directed to the interpretation of statutory provisions in a way which is compatible with the human right in question, as identified and described in Part 2, including, where it has been engaged, s 7(2). Heydon J observed that, if s 7(2) were valid, it would inform the interpretative task, but his Honour held that both s 7(2) and s 32(1) were invalid.
22 Hayne and Heydon JJ both dissented with respect to the final orders and Heydon J also dissented on the question of whether the appeal should be allowed. It is unnecessary to decide whether, in these circumstances, the Court of Appeal is bound to follow its own decision in Momcilovic unless satisfied that it is clearly wrong."
"142 There being no majority view as to the operation of s 7(2), one must deal with the point in the way that one thinks to be correct. (Great Western Railway Co v Owners of SS Mostyn 1928 AC 57, 53; Federation Insurance Ltd v Wasson [1987] HCA 34; (1987) 163 CLR 303,314). This Court held in Momcilovic that s 7(2) is to be considered only after the statutory provision in question has been interpreted in accordance with s 32(1). In my view it is appropriate to adhere to that approach until and unless the High Court determines that it is incorrect. (Green v R (2011)283 ALR 1, 23-24 [82] - [87] (Heydon J))".
"However, if s 7(2) does not inform the interpretive function, there is no mechanism for the court in interpreting statutory provisions in a rights compatible way to recognise the need for rights to be read together. As the Centre's submission noted, some Charter rights are subject to express limitations. Consideration of whether a statutory provision is compatible with the right of freedom of expression must require determination of whether any apparent limitation is a reasonably necessary limitation within s 15(3) of the Charter. It is a task that may be thought to be of the same character as the determination of whether an apparent limitation on the right of peaceful assembly is demonstrably justified within s 7(2).
683 The Victorian Attorney-General's submission that the question of justification in s 7(2) is part of, and inseparable from, the process of determining whether a possible interpretation of a statutory provision is compatible with human rights should be accepted. It is a construction that recognises the central place of s 7 in the statutory scheme and requires the court to give effect to the Charter's recognition that rights are not absolute and may need to be balanced against one another.".
"(d) the organisation reasonably believes that the use or disclosure is necessary to lessen or prevent-
(ii) a serious threat to public health, public safety, or public welfare; or
(e) the organisation has reason to suspect that unlawful activity has been, is being or may be engaged in, and uses or discloses the personal information as a necessary part of its investigation of the matter or in reporting its concerns to relevant persons or authorities; or
(f) the use or disclosure is required or authorised by or under law; or
(g) the organisation reasonably believes that the use or disclosure is reasonably necessary for one or more of the following by or on behalf of a law enforcement agency-
(i) the prevention, detection, investigation, prosecution or punishment of criminal offences or breaches of a law imposing a penalty or sanction;".
Whether the ordinary meaning of IPP 4.2 is compatible with the Complainant's rights
"1. Everyone has the right to respect for his private and family life, his home and his correspondence.
"49. In the present case, the Commission has noted the following elements: first, there was no intrusion into the "inner circle" of the applicant's private life in the sense that the authorities entered his home and took the photographs there; secondly, the photographs related to a public incident, namely a manifestation of several persons in a public place, in which the applicant was voluntarily taking part; and thirdly, they were solely taken for the purposes, on 17 February 1988, of recording the character of the manifestation and the actual situation at the place in question, e.g. the sanitary conditions, and, on 19 February 1988, of recording the conduct of the participants in the manifestation in view of ensuing investigation proceedings for offences against the Road Traffic Regulations.
"67. The mere storing of data relating to the private life of an individual amounts to an interference within the meaning of Article 8 (see Leander v. Sweden). The subsequent use of the stored information has no bearing on that finding (Amann v. Switzerland). However, in determining whether the personal information retained by the authorities involves any of the private-life aspects mentioned above, the Court will have due regard to the specific context in which the information at issue has been recorded and retained, the nature of the records, the way in which these records are used and processed and the results that may be obtained (see, mutatis mutandis, Friedl, cited above and Peck v. the United Kingdom, cited above)."
"45. ...The Metropolitan Police, visibly and with no obvious cause, chose to take and keep photographs of an individual going about his lawful business in the streets of London. This action is a good deal more than the snapping of the shutter. The police are a State authority. And as I have said, the appellant could not and did not know why they were doing it and what use they might make of the pictures.
"This cluster of values, summarised as the personal autonomy of every individual and taking concrete form as a presumption against interference with the individual's liberty, is a defining characteristic of a free society. We therefore need to preserve it even in little cases. At the same time it is important that this core right protected by Article 8, however protean, should not be read so widely that its claims become unreal and unreasonable. For this purpose I think there are three safeguards, or qualifications. First, the alleged threat or assault to the individual's personal autonomy must (if Article 8 is to be engaged) attain "a certain level of seriousness". Secondly, the touchstone for Article 8(1)'s engagement is whether the claimant enjoys on the facts a "reasonable expectation of privacy" (in any of the senses of privacy accepted in the cases). Absent such an expectation, there is no relevant interference with personal autonomy. Thirdly, the breadth of Article 8(1) may in many instances be greatly curtailed by the scope of the justifications available to the State pursuant to Article 8(2). I shall say a little in turn about these three antidotes to the overblown use of Article 8."
"We can see, then, that while an individual's personal autonomy makes him the master of all those facts about his own identity of which the cases speak, his ownership of them depends by law on there being a reasonable expectation in the particular case that his privacy will be respected. This may operate as a factor limiting the scope of the Article 8 right."
The requirements of the Public Records Act
Evidence obtained through surveillance devices and telephone intercepts
Destroy when required in accordance with the relevant governing legislation
Records of evidence gathered during the investigation of crimes that are not incorporated into briefs of evidence. Includes audio visual records such as in car recordings, station and cell recordings and recordings of interviews
Records documenting ongoing assessment of the severity of threats made or considered to be posed by persons or groups including religious, ideological and issue related groups in relation to public order or an event
Records documenting non-ongoing (one-off) assessments of the severity of threats relating to events. Includes threat assessments for planned events such as sporting, cultural or political events or planned protests.
Records documenting the planned Police response to events such as demonstrations, State funerals and annual sporting events and visits of prominent persons such as persons of public office. Includes operation orders, threat assessments, briefings and plans for Police presence and Police tactics including contingency plans. Also includes records of liaison with event organisers, pre event briefings, deployment and post event reviews.
"Description: Master Recordings: Unedited, Not Required as Evidence Refers to original high quality masters or original recordings which may have been migrated (unedited). Disposal action: Temporary Destroy 3 months after decision made not to proceed or when operational/administrative use is concluded Example of Records: In Car Recordings Station and Cell Recordings Interviews "
"38. (1) Subject to this section, it is unlawful for a public authority to act in a way that is incompatible with a human right or, in making a decision, to fail to give proper consideration to a relevant human right.
(2) Subsection (1) does not apply if, as a result of a statutory provision or a provision made by or under an Act of the Commonwealth or otherwise under law, the public authority could not reasonably have acted differently or made a different decision.
39. (1) If, otherwise than because of this Charter, a person may seek any relief or remedy in respect of an act or decision of a public authority on the ground that the act or decision was unlawful, that person may seek that relief or remedy on a ground of unlawfulness arising because of this Charter."
"In my opinion, s39(1) cannot be invoked as the source of VCAT's power to engage in collateral review on Charter grounds. There are two reasons for this. First, as is plain, the section does not confer upon VCAT any power of judicial review. Secondly, the section does not expand any power of collateral review that VCAT might have under ordinary common law principles...
Indeed, it can be argued that the legislative intention disclosed by s 39 is that Charter unlawfulness can be relied upon as a ground in - and only in - a proceeding the object of which is to seek 'relief or remedy in respect of an act or decision of a public authority on the ground that...[it] was unlawful'. That would, by definition, confine such relief to a direct challenge before VCAT, and would exclude any possibility of collateral review."
Caripis
Victoria Police
(1987) 163 CLR 303
(1998) 194 CLR 355