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What’s in a face? Sam Grover
6 October 2016


When an individual asks for privacy, what steps should an agency take to ensure that he or she is sufficiently anonymised? This was an issue that the Broadcasting Standards Authority (BSA) grappled with in a recent decision.

The context

The TV show Dog Squad follows working dogs in a variety of settings. On the episode in question, the show was filming dogs that worked for the Ministry of Primary Industries in an airport. The dogs were sniffing incoming tourists’ luggage for potential biohazards such as fruit and vegetables.

One of the dogs detected an apple in a couple’s luggage, which led a quarantine officer to question the couple then issue them with a fine. The quarantine officer was not comfortable with being filmed, so his name was withheld and his face was blurred.  

The complaint

When the episode aired, the quarantine officer complained to the BSA, saying that the show had breached his privacy by running footage of him fining the couple. He argued that blurring his face and ID tag did not sufficiently anonymise him, as there were a number of other identifying characteristics, which, when put together, served to identify him anyway.

The BSA agreed that in spite of his blurred face, he was still identifiable. However, it did not hold up his complaint because the footage was taken in a public place. He could have conceivably been seen or filmed by almost anyone who happened to be in his place of work. This could also happen to a librarian, police officer, rubbish collector or anyone who works in a public place.

Some guidance

The biggest lesson we can take from this case is the fact that the BSA found the blurring of the officer’s face was insufficient to anonymise him. This is an example of reidentification, which is when details that are purportedly anonymised become identifiable when they cross-referenced against other data. In this case, anyone who met the quarantine officer could identify him as the subject of the show based on things like his hairstyle, his voice, his uniform, his job title and his work location. This was in spite of the fact that his face and name had been blurred.

While the BSA ultimately did not uphold the complaint, it still serves as a cautionary tale. If you anonymise personal details in some way, you need to take sufficient steps to ensure that they are truly anonymous and not prone to reidentification. Otherwise, you can run the risk of inadvertently breaching someone’s privacy. 

Image credit: Pau Reta via Flickr.


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