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How would Durant affect subject access requests for photos that were not indexed by name or other obvious identifying information?

Following a recent protest I attended in the City of Westminster, the organisers were threatened by the Council with prosecution for "littering" ie. handing out leaflets and "criminal damage" for putting up demonstration posters on lamp-posts using blu-tack....

Assuming that the photos were not processed automatically in any form (e.g. the police did not use electronic cameras), the images would still constitute personal data. However as category (e) data held by a public authority, only the right of access and correction would apply.

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