Ports of Jersey and Identity Cloak

#The Governance Challenge: Balancing Access Rights with Privacy Obligations 

Responsibility for data protection and governance at Ports of Jersey sits with a small but highly experienced team. 

Nia Richardson serves as Data Protection Officer, Company Secretary and Corporate Governance Manager, while Szilvia Hausel supports governance, compliance and operational data protection activities across the organisation. 

Together, they oversee compliance with Jersey’s data protection regulations, staff training, incident response procedures and governance standards. Their role is both strategic and highly practical. 

Training extends beyond standard e-learning modules. Scenario-based exercises help staff to recognise data protection risks, escalate incidents appropriately and manage sensitive information responsibly in real-world operational settings. 

This practical mindset also applies to CCTV governance. 

Ports of Jersey has historically experienced relatively few subject access requests relating to video footage. Most requests arose from minor incidents, such as passengers slipping or falling within terminals or harbour areas. Occasionally, solicitors requested footage linked to insurance claims or disputes. Residents also sometimes requested access to footage involving themselves. 

More recently, however, the governance team began identifying a wider trend. 

Public understanding of data rights has increased significantly in recent years. Individuals are more aware of what organisations can and cannot do with personal data and increasingly are exercising their rights of access. 

That change is beginning to affect transport operators across Europe and the British Isles. 

Ports of Jersey has seen a noticeable increase in requests linked to refused boarding incidents, often involving disputes around passport validity, travel documentation or post-Brexit residency rules between the UK and EU member states. Passengers who believe they were incorrectly denied boarding may request CCTV footage as part of complaints, insurance matters or legal advice processes. 

In parallel, law enforcement agencies remain frequent requesters of video footage for operational and evidential purposes. 

Ports of Jersey may also receive requests from commercial partners, including airlines, ferry operators, freight carriers and retail concessionaires. However, the governance team maintains strict controls around disclosure. Footage is only shared when requests meet clearly defined legal, operational and proportionality thresholds. 

This is where the complexity begins. 

#The Solution: Identity Cloak and Intelligent Dynamic Redaction 

After reviewing available options, Ports of Jersey selected Facit’s Identity Cloak. 

The decision was driven primarily by the software’s automated dynamic redaction capability. 

Unlike traditional manual blurring tools, Identity Cloak uses AI-powered tracking of individuals continuously through video footage. Rather than relying on operators to manually reposition redaction boxes frame by frame, the software dynamically tracks movement throughout the scene. 

Automated tracking significantly reduces manual workload while improving consistency and reliability. 

Importantly, the software does not use facial recognition technology. 

That distinction mattered greatly to Ports of Jersey. 

The AI functionality identifies shapes and movement patterns for tracking purposes, but it does not attempt to identify specific individuals. Facial recognition would not align with Ports of Jersey’s data capture policies or governance principles. 

Identity Cloak’s tracking technology enabled the organisation to improve operational efficiency without expanding into more intrusive forms of biometric surveillance. 

Another deciding factor was Identity Cloak’s zoom and crop functionality. 

Many CCTV cameras across airport and harbour environments monitor wide operational areas. Subjects may appear relatively small or distant within frame. The ability to zoom into footage while maintaining effective redaction controls proved especially valuable for Ports of Jersey’s operational environment. 

Just as important was ease of Implementing a new system.

Identity Cloak integrated cleanly with Ports of Jersey’s existing video management systems, which avoided the need for disruptive infrastructure replacement or complex redesign. 

For a resource-conscious organisation where staff routinely manage multiple responsibilities, uncomplicated integration was a major advantage. 

Only four authorised users currently operate Identity Cloak directly, alongside support from the IT department. Despite the relatively low volume of SARs at present, early feedback from users has been consistently positive. 

The system has proven intuitive, straightforward to learn and significantly more efficient than previous approaches. 

As Nia Richardson summarises: 

“We really like Identity Cloak. Identity Cloak is not only very simple, but very effective.” 

#The Results: Future-Ready Compliance and Greater Operational Confidence 

Although implementation remains relatively recent, the benefits of Identity Cloak are already becoming clear. Most importantly, Ports of Jersey now has confidence that it can respond compliantly to increasingly complex video access requests. Requests that would previously have been operationally prohibitive — particularly those involving busy public spaces — are now manageable. 

The software has also improved efficiency for governance staff whose responsibilities extend well beyond CCTV compliance. For a lean team wearing multiple hats across governance, data protection and operational support, reducing manual processing time is critical. The organisation is also better prepared for future demand. Public awareness of data rights is unlikely to diminish. Across both public and private sectors, Subject Access Requests continue to rise as individuals become more familiar with their legal entitlements. 

Ports of Jersey recognised that waiting until request volumes became unmanageable would have been reactive rather than strategic. Instead, the organisation chose to strengthen its governance capabilities early, before operational pressure intensified further. Ports of Jersey’s proactive approach reflects the wider culture within the organisation: balancing operational resilience, legal compliance and public trust across infrastructure that Jersey depends on every day.