DUNEDIN CAMERAS, SPEED ENFORCEMENT, PRIVACY AND REVENUE

OIA / LGOIMA Request Bundle

Dunedin City Council | NZ Transport Agency Waka Kotahi | Ministry of Justice

Purpose of this bundle This bundle is designed to triangulate the whole camera-ticket-money-data chain: who owns the cameras, who pays for them, who operates them, who accesses the data, who receives infringement revenue, who verifies accuracy, and how privacy safeguards are documented.

Working theory

DCC may say it does not operate speed/safety enforcement cameras.

NZTA may say revenue goes to the Crown rather than directly to NZTA.

Police and/or the Ministry of Justice may hold parts of the enforcement, unpaid-fines, prosecution, transfer, and collection data.

Therefore the request is structured across DCC, NZTA and the Ministry of Justice so that each agency must either answer, transfer, or identify the lawful record-holder.

Key 2019 DCC admissions to use as baseline

Area	2019 DCC position
Property CCTV	212 CCTV cameras in or around DCC facilities.
Traffic cameras	36 traffic cameras across Dunedin roads; split DCC 15 and NZTA 21.
Parking	2 stand-alone CCTV cameras in parking buildings and 11 body-worn cameras for parking wardens.
ANPR	DCC said there were no ANPR cameras and CCTV was not deployed for automatic number plate recognition.
Analytics / facial recognition	DCC said it used no analytics and no facial recognition.
Vehicle tracking	All Council fleet vehicles were tracked through Eroad, with some extra tracking/communication tools for officer safety.
Software / brands	Property mainly used Avigilon; traffic cameras were Axis and connected to FLIR Control Center.
Access	Requests to access footage had to go to the DCC Privacy Officer and be approved by Senior Leadership Team.
Disclosure records	The policy stated that all requests to access footage and the decisions made would be held on record.

Source baseline: Dunedin City Council response dated 11 September 2019, “LGOIMA request for information on cameras and CCTV”.

 

REQUEST 1 – DUNEDIN CITY COUNCIL

Subject: LGOIMA Request – Dunedin Cameras, Speed-Limit Enforcement, Infringement Revenue, Privacy, Data Sharing, Signage and Safety Justification

Dear Dunedin City Council,

I request information under the Local Government Official Information and Meetings Act 1987.

This request concerns the use of cameras, traffic cameras, CCTV, body-worn cameras, monitoring cameras, speed/safety cameras, data systems, infringement revenue, speed-limit reductions, signage, privacy impacts, and any connection between local road-control decisions and ticketing/enforcement outcomes in Dunedin.

This request follows DCC’s prior LGOIMA response dated 11 September 2019 concerning cameras and CCTV, in which DCC stated that it had multiple camera/CCTV networks operated by its property, transport and parking departments. That response stated, among other matters, that DCC had 212 CCTV cameras in or around DCC facilities, 36 traffic cameras in Dunedin split between DCC and NZTA, two stand-alone parking-building cameras, eleven body-worn cameras for parking wardens, no ANPR cameras, no facial recognition, no camera analytics, and footage access controlled through the DCC Privacy Officer and Senior Leadership Team.

The public is entitled to know what has changed since then, who now operates each camera system, who accesses the footage, who receives revenue or financial benefit from infringements, and whether the word “safety” is being used as a genuine harm-reduction term or as a financial, enforcement or infrastructure investment justification.

1. Current camera systems in Dunedin

Please provide the current number, category, purpose and location of all camera systems operated by, for, with, or in relation to DCC, including CCTV cameras, traffic cameras, parking cameras, body-worn cameras, mobile cameras, temporary cameras, event cameras, cameras on Council vehicles, monitoring cameras, speed/safety cameras, red-light cameras, average-speed cameras, ANPR-capable cameras, cameras operated by contractors, and cameras operated by NZTA, Police, WTOC, or other agencies on roads or assets involving DCC.

For each category, please provide location, owner, operator, funding source, purpose, whether the camera records, livestreams, monitors only, detects speed, detects red-light offences, recognises plates, or stores metadata, and whether DCC has live access, recorded access, indirect access, or no access.

2. Speed-limit reductions and enforcement-camera interaction

Please provide all documents, reports, business cases, safety assessments, consultation material, mapping material, internal memoranda, meeting notes and decision papers from 1 January 2019 to the date of this request concerning reductions of speed limits in Dunedin, including 100 km/h to 80 km/h, 80 km/h to 60 km/h, 60 km/h to 50 km/h, 50 km/h to 40 km/h, and 40 km/h to 30 km/h.

Please include the locations of those speed-limit reductions, the safety justification for each reduction, crash-history evidence relied on, pedestrian, school, cycleway, roadworks, congestion, urban-design or climate-policy justifications relied on, and any relationship between speed-limit changes and camera deployment.

Please provide any material showing whether expected infringement numbers or revenue were modelled before or after speed-limit reductions, including whether DCC, NZTA, Police, or any contractor assessed likely ticket volumes from reduced speed thresholds.

Please provide any maps, GIS files, or schedules showing current and historical Dunedin speed-limit zones, including dates of change.

3. Signage, notice and enforceability

Please provide all current policies, standards, audits, inspections, complaints, correspondence and legal advice concerning speed-limit signage in Dunedin, whether speed-limit changes are adequately signed, whether 30 km/h, 40 km/h, 50 km/h, 60 km/h, 80 km/h and 100 km/h zones are clearly mapped and signposted, and how DCC ensures motorists have proper notice of the applicable speed limit.

Please include documents showing how GPS mapping errors or incomplete mapping are addressed, complaints about unclear, missing, inconsistent or poorly placed signs, whether any infringement notices have been challenged because of signage defects, and whether any enforcement sites were reviewed due to inadequate signage.

Please provide all signage audit records for speed-limit areas where camera enforcement has occurred or is proposed.

4. Ticketing, infringement revenue and financial benefit

Please provide, for each financial year from 1 January 2019 to the date of this request, the total number of speed-camera infringements issued in Dunedin, red-light-camera infringements issued in Dunedin, parking-camera or camera-assisted parking infringements issued in Dunedin, total face value of those infringements, total amount paid, total amount unpaid, total amount transferred to the Ministry of Justice for enforcement, and total amount remitted, waived, cancelled or withdrawn.

Please identify the total amount retained by DCC, if any, and the total amount received by NZTA, Police, Ministry of Justice, the Crown, or any contractor.

Please state whether any part of the money is returned to local road safety, DCC transport budgets, Police, NZTA, road contractors, consultants, or camera providers.

If DCC says it does not hold this information, please transfer this part of the request to the agency that does hold it, including NZTA, Police and/or Ministry of Justice.

5. “Safety” as justification, investment or funding model

Please provide all documents from 1 January 2019 to the date of this request using, defining, relying on, or modelling the concept of “safety” in relation to camera deployment, speed-limit reductions, traffic-calming, road redesign, infringement enforcement, funding applications, NZTA investment approvals, business cases, public consultation, and political or Council decision-making.

Please include any documents showing whether “safety” has been treated as a public-safety outcome, an investment category, a funding justification, a benefit-cost input, a basis for enforcement expansion, or a justification for collecting, retaining or disclosing personal information.

6. Camera accuracy, calibration and evidential reliability

Please provide all documents concerning the accuracy, calibration, testing, verification, maintenance and evidential reliability of any camera system used in Dunedin for infringement, enforcement or compliance purposes.

This includes calibration certificates, maintenance records, manufacturer specifications, error-rate assessments, vibration/movement assessments, site-specific testing, line-of-sight assessments, camera angle assessments, point-of-focus documentation, whether cameras target a vehicle, plate, driver, registered owner, or moving object, and whether vibration, vehicle movement, trailer movement, road angle, weather, obstruction, glare or lens distortion can affect readings.

Please provide any known false-positive, rejected-image or disputed-reading data, and the process used to decide whether an infringement is issued, rejected, manually reviewed or withdrawn.

7. Owner liability versus driver identification

Please provide all documents explaining whether camera-based infringements in Dunedin are issued against the driver, registered owner, person in possession of the vehicle, company or fleet operator, rental-car company, or another nominated person.

Please provide all policies and forms relating to nomination of the driver, transfer of liability, company vehicles, rental vehicles, disputed identity, and situations where the owner was not driving.

Please also provide any documents explaining whether camera images are used to identify the driver or merely the vehicle/registration plate.

8. ANPR, facial recognition, analytics and data extraction

Please confirm whether DCC, NZTA, Police, WTOC, contractors, or any related party uses, has access to, has trialled, has procured, or has considered ANPR, facial recognition, AI video analytics, object recognition, vehicle classification, person tracking, crowd monitoring, pattern-of-life analysis, retrospective video search, average-speed calculation, red-light detection, mobile-phone detection, seatbelt detection, vehicle tracking through multiple cameras, or metadata extraction from footage.

For each system, please provide product name, supplier, operator, purpose, date acquired, trialled or considered, whether the system is active, inactive, proposed, trialled or discontinued, privacy impact assessment, legal advice, procurement documents, contracts, data-retention rules, and agencies or contractors with access.

9. Privacy, personal information and data retention

Please provide all current privacy impact assessments, policies, procedures, data-retention schedules, access forms, privacy notices, signs, legal advice and operational guidelines relating to CCTV, traffic cameras, body-worn cameras, speed/safety cameras, red-light cameras, ANPR, average-speed cameras, Police access, NZTA access, contractor access, Ministry of Justice transfer, and storage of images, video, plates, vehicle details, driver/occupant images, metadata or infringement records.

Please state what personal information is collected, whether faces are captured, whether vehicle occupants are captured, whether number plates are captured, whether non-offending vehicles are captured, whether rejected images are deleted, how long each category of information is retained, who has access, who can copy, export or transfer footage, and whether any data is stored overseas or on cloud systems.

10. Access logs, Police requests and third-party disclosure

Please provide, from 1 January 2019 to the date of this request, the number of requests for DCC camera footage, number granted, number declined, number made by Police, NZTA, Ministry of Justice, insurers, lawyers, private investigators, contractors, members of the public, and the access register, request register, approval register or equivalent record.

For each request, please provide date, requesting agency or party, general reason, camera/location involved, whether access was granted or declined, whether footage was viewed only, copied, exported, transferred or disclosed, approving officer or role, and statutory basis relied on.

Personal identifying information may be redacted if necessary, but the existence, category, date, agency, purpose and decision should not be withheld.

11. Contracts, suppliers, donors, campaign connections and conflicts of interest

Please provide all documents from 1 January 2019 to the date of this request concerning contracts for cameras, camera software, infringement systems, analytics, storage, monitoring, maintenance, signage, traffic modelling or speed-limit-change advice; supplier names; procurement decisions; tender documents; scoring documents; conflict-of-interest declarations; and elected-member declarations relevant to transport, cameras, road safety, contractors or campaign donors.

Please provide documents concerning donations, sponsorships, lobbying, meetings or communications involving camera suppliers, road-safety contractors, transport consultants, parking providers, enforcement contractors, or related companies.

Please provide any records showing any relationship between mayoral/councillor campaign donors and companies benefiting from transport, safety, camera, signage, enforcement, parking, monitoring or road redesign contracts.

If DCC holds no such records, please state what searches were undertaken and by whom.

12. NZTA / Police / WTOC involvement

Please provide all memoranda of understanding, protocols, agreements, service-level agreements, operational arrangements, correspondence, access agreements and governance documents between DCC and NZTA/Waka Kotahi, New Zealand Police, Wellington Transport Operations Centre, Ministry of Justice, any camera provider, any enforcement contractor, any data-hosting or cloud provider, and any transport analytics provider.

Please include documents showing who owns the cameras, who pays for them, who operates them, who accesses them, who receives infringement data, who receives revenue, who is responsible for privacy compliance, who is responsible for signage and public notice, and who is responsible for responding to access or correction requests under the Privacy Act.

13. Complaints, disputes, withdrawals and proven errors

Please provide, from 1 January 2019 to the date of this request, the number of camera-based infringements challenged, withdrawn, cancelled due to error, cancelled due to signage issue, cancelled due to camera or calibration issue, cancelled due to wrong vehicle, wrong owner or wrong driver, referred to court, and where DCC, NZTA, Police or Ministry of Justice accepted an error.

Please provide all reports, audits or reviews into camera errors, signage defects, privacy breaches or enforcement defects.

14. Refusal and transfer requirements

If DCC does not hold any part of this information but believes another agency does, please transfer that part of the request under the appropriate statutory provision and advise me of the transfer.

If any part is refused or withheld, please identify the specific statutory ground relied on, the specific information withheld, whether partial release with redactions was considered, the public interest factors considered, the role of the decision-maker, and the searches undertaken before claiming information is not held.

Please treat this as a request for formal and operational records, not as a request for every internal email unless the email is the only record of a decision, approval, access request, transfer, disclosure, contract, safety justification, or privacy assessment.

Yours faithfully,

[Name]

 

REQUEST 2 – NZ TRANSPORT AGENCY WAKA KOTAHI

Subject: OIA Request – Dunedin Safety Cameras, Speed-Limit Changes, Infringement Revenue, Privacy, Accuracy and Data Retention

Dear NZ Transport Agency Waka Kotahi,

I request information under the Official Information Act 1982.

This request concerns all NZTA-operated, NZTA-funded, NZTA-accessed or NZTA-approved safety cameras, speed cameras, red-light cameras, average-speed cameras, mobile camera units, trailers, SUVs, ANPR-capable systems, and traffic-monitoring cameras in Dunedin and the wider Dunedin City Council area.

Please provide the following from 1 January 2019 to the date of this request.

1. Camera locations and operation

Please provide a list of all NZTA camera locations in Dunedin, including fixed speed cameras, mobile speed camera locations, safety camera trailers, SUV/mobile camera operations, red-light cameras, average-speed cameras, traffic-monitoring cameras, ANPR-capable cameras, and proposed or planned camera sites. For each, please provide the installation date, operating date, speed limit, road-controlling authority, operator, system type, and whether DCC was consulted.

2. Infringements and revenue

For each camera site and each financial year, please provide number of infringements issued, face value of infringements issued, amount paid, amount unpaid, amount transferred to Ministry of Justice, amount cancelled, withdrawn or waived, number challenged, number upheld, number rejected before issue, and number not issued due to image/data defect. Please identify where the money goes, including the Crown bank account / Consolidated Fund, Ministry of Justice, NZTA, Police, or any contractor.

3. Speed-limit reductions and ticket-volume impact

Please provide all modelling, analysis, memoranda, advice, business cases or reports assessing whether speed-limit reductions in Dunedin would increase infringement numbers, increase infringement revenue, change driver behaviour, reduce death or serious injury, affect travel time, require new signage, require camera relocation or recalibration, or require public notice or education.

4. Accuracy and calibration

Please provide all accuracy, calibration, certification, testing and maintenance records for camera systems used in Dunedin, including calibration certificates, testing records, manufacturer specifications, site-approval documents, manuals, error-rate material, disputed-reading records, vibration/movement/glare/weather limitation assessments, rejected-image rates, and the human-review process before infringement issue.

5. Data and privacy

Please provide all privacy impact assessments, data-retention schedules, access policies, deletion rules, data-sharing agreements, cloud-hosting records and privacy notices for camera systems operating in Dunedin. Please specifically state whether number plates, vehicle occupants, faces, and non-offending vehicles are captured; whether ANPR, facial recognition or AI analytics are used; whether rejected images are immediately deleted; how long infringement images/videos and accounting/infringement records are retained; who has access; and whether Police, DCC, Ministry of Justice or contractors have direct access.

6. Contracts and suppliers

Please provide all contracts, supplier names, procurement records, business cases and funding documents for cameras, software, storage, analytics, infringement processing, calibration, maintenance and signage used in Dunedin.

7. DCC involvement

Please provide all correspondence, agreements, minutes, meeting notes, consultation records and decisions involving DCC in relation to camera placement, speed-limit reductions, signage, enforcement sites, public communication, road-safety funding, privacy, infringement data, and access to footage or camera feeds.

Yours faithfully,

[Name]

 

REQUEST 3 – MINISTRY OF JUSTICE

Subject: OIA Request – Dunedin Camera Infringements Transferred for Enforcement and Revenue Received

Dear Ministry of Justice,

I request information under the Official Information Act 1982.

Please provide, from 1 January 2019 to the date of this request, for Dunedin and the Dunedin City Council area:

1. number of speed-camera infringements transferred to the Ministry of Justice for enforcement;
2. number of red-light-camera infringements transferred;
3. total face value transferred;
4. total enforcement fees added;
5. total amount collected;
6. total amount unpaid;
7. total amount written off;
8. total amount paid into the Crown / Consolidated Fund;
9. number of driver licence stop orders issued in relation to camera-based infringements;
10. number of enforcement actions taken;
11. any records showing whether the original infringement was issued by NZTA, Police, DCC or another body.

Please also provide any policy documents explaining how camera-based infringement debts are enforced after transfer to the Ministry.

Yours faithfully,
[Name]

 

PUBLIC-FACING SUMMARY FOR WEBSITE / FACEBOOK

Dunedin’s camera system needs daylight.

DCC admitted in 2019 that it had hundreds of CCTV cameras, traffic cameras, parking cameras and body-worn cameras. At that time it said there was no ANPR, no facial recognition and no analytics.

That was 2019.

Since then, speed limits have been reduced across many areas – 30, 40, 50, 60, 80 and 100 km/h zones – and the public is expected to comply, even where signage and GPS mapping may be unclear.

The core questions are simple:

Who owns the cameras?
Who operates them?
Who pays for them?
Who gets the ticket money?
Who gets the data?
Who checks the cameras are accurate?
Who decides “safety” means more surveillance and more fines?
Who profits from the system?

We are sending formal information requests to DCC, NZTA and Ministry of Justice to follow the whole chain: cameras, speed-limit changes, ticketing, revenue, privacy, contractors, campaign connections, data retention and enforcement.

This is not anti-safety.

This is pro-accountability.

Public roads should not become private data farms or automated revenue corridors hidden behind the word “safety”.