Mobile Finger Print Mobile ID

Transcription

1 Mobile Finger Print Mobile ID Manual of Policy and Guidance Mobile Fingerprint Identification Devices Document Information Document Status & Version Version 1.2 Version Date 28 th February 2011 Author(s) Paul Palmer Owner Ch Supt Leeney

2 Document Control Document Information Document Location Quality Reviewers Name Role Sections Reviewed Version History Version Date Requestor of Change Summary of Change(s) Distribution List Name Department / Organisation Project Role Document Name: Mobile ID Document Status: V1 Page ii

3 Mobile ID Program Board Chief Supt Leaney Operations working group Chair Supt Greenhalgh Hardware Controller Paul Palmer Project manager Mike Jenkins Operational staff users TBA Technical group ICT lead TBA Hardware controller Paul Palmer Project manager Mike Jenkins ICT and networks staff Document Name: Mobile ID Document Status: V1 Page iii

4 Table of Contents 1 INTRODUCTION DEVICES IN USE IDENTIFICATION WORK-FLOW FINGERPRINT IDENTIFICATION LEGALITY Section 61 PACE and Code D Use of Force Taking Fingerprints by Consent Taking Fingerprints without consent or Power European Convention of Human Rights General Conduct PROCEDURAL RECORD KEEPING Pre Sample Post sample File Deletion Evidential Documentation and Court Reports SECURITY CONSIDERATIONS Data Security Device Password Personal Password Display of Data Unauthorised Connections Physical Security Security Compromise Incidents...8 Document Name: Mobile ID Manual of Guidance Page iv

5 7 MAINTENANCE AND ASSET MANAGEMENT Daily Checks Mains Charging In-Car Charging After Use Asset Management Fault Reporting Users Account Problems New users SUPERVISION STRATEGY AND DEPLOYMENT MobileID High Level Force strategy Operational Strategy Deployment and Use HEALTH AND SAFETY Potential Weapon Unsecured Projectile Body Fluids and Contagious Disease Contamination Suspected Improvised Explosive Devices (IEDs) Display Screen Equipment Regulations (DSE) Distractions to the Driver Electromagnetic Emissions LEGAL CONSIDERATIONS AND REQUIREMENTS Data Protection Act Computer Misuse Act The Representation of the People (England and Wales) (Amendment) Regulations Section 3 of the Road Traffic Act Document Name: Mobile ID Manual of Guidance Page v

6 10.5 Regulation 104 of the Road Vehicles (Construction and Use) Regulations Force Policy and Procedures (FPPs)...18 Document Name: Mobile ID Manual of Guidance Page vi

7 1 INTRODUCTION This document is presented as an operational Manual of Guidance regarding the use of Mobile Fingerprint Identification Devices (Referred to under the generic title of MobileID) Developments in information technology within the policing sector have provided numerous opportunities to enhance and improve the quality of information tools that the frontline police officer has at their disposal for the prevention and detection of crime. The introduction of the Mobile ID Device, through trials conducted by the National Policing Improvement Agency (NPIA) has reached a stage where widespread deployments of such devices have now become a reality. Due to the high usage of the previous mobile finger print technology (Project Lantern) Surrey Police were selected by the NPIA to be an early adopter force along with Greater Manchester Police to trial the new technology. 2 DEVICES IN USE Second generation (and current phase) devices are provided for Surrey Police by Cogent Systems, and the devices themselves are referred to as MI2 and MI3 (Mobile Information 2 or 3) and the Blackberry/Blue Check device. The MI3 device and the Blackberry/Blue check are ready for delivery to Surrey Police, where as the MI2 is still in its post-development phase and at the time of presenting this document, is not commercially ready for delivery. Through out this document, all such units, regardless of their design and brand names, will be referred to simply as the device Document Name: Mobile ID Manual of Guidance Page 1

8 All the devices in use work by taking an electronic scan of the index fingers of the right and left hand of the subject, and then comparing them to a database of known persons. This database is referred to as the Ident1 database. Ident1 contains fingerprint details of any person whose details appear on the National Criminal Records Office database (CRO). Typically, these will only be people that have been arrested for and subsequently convicted (which includes cautions and penalty notices) of an offence and therefore allocated a CRO number. This differs from a PNC ID number which is allocated to a person upon their first arrest. 3 IDENTIFICATION WORK-FLOW The following is an example typical of the processes undertaken during a street encounter involving a Mobile ID Device. Subject stopped/encountered after committing offence Subject provides personal identification details Officer invokes PACE Code D power or obtains consent to take fingerprints Mobile ID Device powered on Fingerprint scan data sent by secure mobile link to Ident1 Database for comparison Comparison result returned to Officer Officers suspects details to be false or inaccurate Officers make reasonable efforts to establish correct details AND Provide subject opportunity to declare correct details Device Password entered Officer ID and Password entered Initial Subject Details entered Scan taken of left and right index fingers Officer records Transaction Reference Number If positive result returned, officer conducts PNC check via Control Room or MDT Final resolution of incident (Arrest/PND/verbal warning/report for summons/nfa etc) Document Name: Mobile ID Manual of Guidance Page 2

9 4 FINGERPRINT IDENTIFICATION LEGALITY As of 7 th March 2011, an amendment to Section 61 of the Police and Criminal Evidence Act 1984 and it associated Code D, granted powers specifically for the use of MobileID devices Prior to this, there is no legal power to require a person to provide a fingerprint for the purposes of identification other than consent. 4.1 Section 61 PACE and Code D The full and detailed wording of the amendment to Section 61 of PACE can be found in both the Police National Legal Database (PNLD) and in the NPIA circular dated 24 th February However, the amendment provides the power: 6a) A constable may take a person s fingerprints without the appropriate consent if: a) the constable reasonably suspects that the person is committing or attempting to commit an offence, or has committed or attempted to commit an offence; and b) either of the two conditions mentioned in subsection 6b is met: 6b) The conditions are that: a) The name of the person is unknown to, or cannot be readily ascertained by, the constable. b) The constable has reasonable grounds for doubting whether a name furnished by the person as his name is his real name The change to Code D PACE reinforces the requirement of officers to ensure that they record their actions appropriately and fully at all times. It is also a requirement that before exercising any power under this legislation, officers must: Inform the person of the nature of the suspected offence, and why they are suspected of committing it. Give the person a reasonable opportunity to establish their real name before deciding: o Their name is unknown and can not be readily ascertained or Document Name: Mobile ID Manual of Guidance Page 3

10 o That there are reasonable grounds to doubt that a name given is their real name. Inform them of the reason why; o Their name is unknown and cant be readily ascertained o Of the grounds for doubting that name given is the real name o Including, for example, why a document provided is insufficient In short, persons that are likely to be subject of fingerprint identification must first be given all reasonable opportunities to establish their real identity. 4.2 Use of Force The legislation provides the power to take fingerprints by force if required, providing that the legal requirements stated in Section 61 PACE and Code D have been fulfilled. Any force used must only be as much as is reasonable, proportionate and justifiable. If force is used to obtain fingerprints, a record of this must be made in line with the local arrangements for Use of Force Recording Procedures. 4.3 Taking Fingerprints by Consent Prior to the acceptance in law of the amendments to PACE, the only power to take fingerprints for identification purposes was by consent. With effect from 7 th March 2011, consent will no longer be obtained for the purposes of a MobileID procedure, and such procedures will only be undertaken where the criteria specified in section 4.1 above is fully met and there is a clear operational need to conduct the procedure. 4.4 Taking Fingerprints without consent or Power There are 2 types of circumstance where it is deemed acceptable to take a person fingerprints without a lawful power or their express consent. Unconscious Persons the police duty of care to such a person justifies the use of MobileID to be able to identify that person in order to ensure that they are provided with the best level of care possible (such as a person found unconscious and then identified, with a marker shown on PNC to state that the person suffers with diabetes this information can be passed to health care professionals in charge of that persons welfare) Document Name: Mobile ID Manual of Guidance Page 4

11 Dead Bodies the Coroner s Rules permit the use of fingerprints to assist in the identification of unknown corpses. Furthermore, it can assist in reducing the trauma to a deceased person s next of kin if an early identification can be made without them being present. 4.5 European Convention of Human Rights The ECHR is intended to protect the rights of all persons, regardless of their suspected involvement in the commission of a crime. All operational officers should have received training in the application of this legislation in an operational policing role, and so it will not be quoted in full here. However, officers are reminded that the following articles of the ECHR need to be considered when conducting a Mobile ID procedure. Article 5 The right to Liberty and Security Article 6 The right to a Fair Trial Article 7 No Punishment without Law Article 8 The right to Respect for Private and Family Life 4.6 General Conduct All policing activities, including Mobile ID procedures, should follow the JAPAN principle: J Justified A Appropriate P Proportionate A Authorised (in law, by instruction, or consent) N Necessary 5 PROCEDURAL RECORD KEEPING Regardless of whether a legal power is exercised, or consent is provided, it is necessary for a record to be kept of the fact that a fingerprint identification using a device has been completed. 5.1 Pre Sample Before the fingerprints are obtained, the circumstances relating to the encounter should be recorded in the officer s personal Pocket Note Book. PACE makes it a requirement that the officer must record in full their reasons for conducting the procedure, including the reasons why the name provided (if any) is suspected of being false, and what steps they have taken to allow the person to provide their correct identity, as per section above. Document Name: Mobile ID Manual of Guidance Page 5

12 5.2 Post sample Once a fingerprint sample has been obtained and compared to the Ident1 database, the device will return a Transaction Reference Number (TRN) - this number will be returned regardless of whether it is a positive identification or not. This TRN must be recorded by the officer for auditing purposes. If a positive identification has been returned, then the details held for the subject (CRO Number, Name, Date of Birth and Gender) should be recorded also. 5.3 File Deletion As previously stated, there is no power at present in law to require a person to provide a fingerprint for identification purposes. The proposed amendment to PACE Code D, will provide a power to obtain a fingerprint for identification purposes, but not for recording purposes. Therefore, it will be a requirement, and is considered best practice now, to delete any files on the Device pertaining to a subject test. The exact method of deletion will be provided during training for the specific device. To prevent the risk of allegations being made at a later stage by a subject, officers should delete the subject files after the test has been completed, in the presence and witness of the subject. Officers may also wish to consider recording this deletion process in their Pocket Note Books and inviting the subject to sign. This process still needs to be completed even in the event of a positive identification which results in a subject s arrest. 5.4 Evidential Documentation and Court Reports When referring to the use of a MobileID device in official documentation such as Statements ad other court papers, officers are required to insert text stating Aided by MobileID Mobile Fingerprinting - officers should refrain from attempting to provide technical details about how the system works. If this is required by the CPS the evidence will be provided by the hardware controller. Likewise, if the encounter that caused the procedure to be completed was finalised by way of issuing a Fixed Penalty Notice, or a Penalty Notice for Disorder, the notice should be suitably endorsed with the text, Identification aided by MobileID Mobile Fingerprinting Document Name: Mobile ID Manual of Guidance Page 6

13 6 SECURITY CONSIDERATIONS 6.1 Data Security The service provided by Cogent Systems is referred to as an end-toend solution, meaning that there is no reliance upon the Surrey Police information networks to complete identification. All data regarding the fingerprint scan and the subject is transmitted from the device, via secure means, to the Cogent back-office facility where comparisons are made to the Ident1 database and the results transmitted back along the same secure path. However, to achieve the security required for handling such data, each device will require two passwords. 6.2 Device Password 6.3 Personal Password 6.4 Display of Data In operational use, all efforts must be made by the officer responsible for the device, that no information on the device is displayed to any unauthorised persons. See Legal Requirements at section 10 below. Document Name: Mobile ID Manual of Guidance Page 7

14 6.5 Unauthorised Connections The devices are equipped with external USB and COM ports. These are exclusively for the loading of software by the manufacturer and for maintenance purposes, and for the charging of the internal batteries. Under no circumstances will a user connect, or allow to be connected, any unauthorised device, which includes, but is not limited to, USB Memory Drives, personal music players, mobile phones, personal organisers or any other digital device. Such connections could compromise the data security of not only the individual device, but also of the data network service. Only authorised persons such as the hardware controller will have access to the administration codes and nominated deputies. Under no circumstances will these passwords be passed onto to non authorised administration personnel. 6.6 Physical Security After the completion of the early adopter stages the devices allocated to Surrey Police through ACPO funding will be distributed to the trained proactive teams that currently use the pilot devices under Operation Lantern. The devices will be distributed between these teams pro rata to the use, ANPR teams core functions relate to stop checking known targets through ANPR technology. The devices will be pooled and deployed at the discretion of the duty sergeant. Some devices will be deployed to Roads Policing units and Uniformed Proactive teams. As such, the individual officer to whom the device has been issued will be expected to assume full responsibility for it whilst on patrol. At no time should the device be left unattended in a vulnerable location or in an unlocked insecure vehicle or location. At no point should the device be left in the possession of any person (police or otherwise) that is not an authorised user. Suspects or other members of the public should never be left unattended in a police vehicle with an unsecured device. When not in use, devices should be stowed out of sight. 6.7 Security Compromise Incidents If at any point, the security of a device should be compromised, action must be taken as a matter of urgency. Document Name: Mobile ID Manual of Guidance Page 8

15 A security compromise will be regarded as any loss, theft or physical misplacing of the device, as well as any suspected breach or disclosure of either a device password or personal password to an unauthorised person. In the event of a compromise, the user must inform their supervisor immediately. A report must then be submitted to the Information Security Officer) containing the following details: Device type and serial number (if known) Type of compromise (Loss, stolen, password breach etc) State of device at time of incident (had the password been entered and therefore the device was unlocked?) Location at time of incident Any suspects if stolen Actions already taken to re-locate the device. In office ours, contact should be made with the Shared Business Service Centre, who will be able to contact Cogent and have the SIM card for the individual device disassociated from the host network. Out of ours a message must be left with the Shared Business Service Centre and the Hardware controller, Mr Paul Palmer to expedite the process above. 7 MAINTENANCE AND ASSET MANAGEMENT 7.1 Daily Checks There are no moving parts on any of the devices available, but prior to commencing a tour of duty with the device; officers will check to make sure that there is no obvious damage to the outer casing, that the device is charged, and that any issued accessories are present in the carry case. Additionally the scan screen should be wiped clean using the cleaning cloth provided with the device 7.2 Mains Charging Each device will be provided with a standard 240 volt mains charging adapter. The device should be left on charge when not in use, with a typical battery life expected to be approximately 12 hours, depending on usage. Document Name: Mobile ID Manual of Guidance Page 9

16 At the end of each tour of duty, the user will replace the device back in the agreed location at the station and ensure it is placed back on charge. Battery management is the responsibility of all users, when returning to base station they must be put on charge, particularly if they are to be handed over to an on coming shift. In car chargers are being looked into for approval also. Battery management is critical to devices,spares will be sourced. 7.3 In-Car Charging There will be a small number of in-car chargers made available to various units, and where available, these should be utilised. When available, more in car chargers will be procured to assist battery management. 7.4 After Use At the end of an operational tour of duty where the device has been deployed, it should be removed from the police vehicle and returned to the designated storage area in the station, and placed on charge. 7.5 Asset Management A central record of the disposition of each device will be held, detailing which unit or office has been allocated a device and an asset number will be issued. Local supervisors are requested not to transfer devices between units without first consulting the asset management team at the airwave office, so that the records can be updated accordingly. 7.6 Fault Reporting If the device is not user serviceable or should a fault develop, contact should be made in the first instance with the Shared Business Service Centre. In turn, they will forward the fault details direct to the equipment supplier, who will then be responsible for arranging any repair or running diagnostic checks with the hardware controller to resolve problems that do not require a device swap out. In the first instance the device will be returned to the hardware controller for diagnostic evaluation. If the hardware controller determines the device is faulty he will, through the Shared Business Service Centre arrange for a replacement device to be delivered to the airwave office for asset management, and deliver the faulty device for collection to the same office so that the faulty device is returned to the supplier Cogent. 7.7 Users Account Problems Document Name: Mobile ID Manual of Guidance Page 10

17 7.8 New users 8 SUPERVISION STRATEGY AND DEPLOYMENT MobileID will deliver a national service which aids the identification of an individual irrespective of which force s area they reside in and where they are stopped. Those who travel to commit crime can no longer rely on practiced personal histories and misleading documentation to avoid identification and are as a result inhibited and exposed to the risk of discovery if stopped. MobileID will help officers save time, not only by avoiding making unnecessary identification arrests but also by making routine identifications more swiftly. 8.1 MobileID High Level Force strategy Document Name: Mobile ID Manual of Guidance Page 11

18 To ensure compliance with the Manual of guidance and force user guides for the safe and appropriate use of MobileID The use of MobileID directly supports policing priorities The use of Mobile ID will support increased visibility and provide live time access to the national identification database Maximise our opportunity to improve data quality and timeliness of submissions To deliver improvements to staff efficiency and effectiveness Bring more offenders to justice who would otherwise avoid prosecution This is seen as an extension to the Surrey Police mobile strategy for the force, and will sit with Ch Supt Leeney and as such the strategic program board will look after the development needs technically, and the use of the devices operationally will sit under this umbrella. The following infrastructure will be implemented to effectively manage the implementation of the Mobile ID project. Chief Supt Leeney Operations working group Chair Supt Greenhalgh Hardware Controller Paul Palmer Project manager Mike Jenkins Operational staff users TBA Technical group ICT lead TBA Hardware controller Paul Palmer Project manager Mike Jenkins ICT and networks staff 8.2 Operational Strategy To support force objectives of Identifying the transient high crime offenders To support force objectives in denying the criminal the use of the road To support force objectives for counter terrorism operations To support and enhance the capability of other mobile technology deployed with our frontline officers To allow officers to make accurate identifications during a street encounter Avoid unnecessary detentions and arrests Improve detection and judicial street disposal process Improve the efficiency of the police custody process Document Name: Mobile ID Manual of Guidance Page 12

19 8.3 Deployment and Use Overall responsibility for the distribution and strategic deployment of MobileID Devices will rest with the Mobile Data Project team. It is anticipated that the devices will predominantly be distributed to ANPR Intercept Team, Roads Policing Teams and other specialist operational units. In order to achieve the Force and Operational Strategy Aims: All trained officers will utilise the device on ALL occasions that the criteria specified in law is met Before concluding any policing encounter with a person that has committed, or is suspected of having committed an offence, officers must be completely satisfied that the identity of the person is fully and accurately established Supervisors are expected to be intrusive and robust in their supervision of staff using MobileID Devices The process will be summarised as Stop - Identify Document or SID 9 HEALTH AND SAFETY As with any policing activity, officers are expected to conduct dynamic risk assessments before embarking upon action. This principle must be extended to the use of Mobile ID Devices. 9.1 Potential Weapon. The Mobile ID Devices are relatively bulky in their design. There is a slim possibility that an aggressive subject may attempt to use the device as a potential weapon to strike an officer. For this reason, the device should not be given to a subject to hold at any point during an ID Procedure. 9.2 Unsecured Projectile The device and its carry case and accessories must not be left insecure on the seats, floor or parcel shelf of a vehicle whilst in motion. In the event of a collision, the device could become a projectile and poses an impact risk to occupants of the vehicle. Document Name: Mobile ID Manual of Guidance Page 13

20 9.3 Body Fluids and Contagious Disease Contamination In routine use, it should not be necessary for the officer using the device to have any direct physical contact with a subject in order to complete a Mobile ID Procedure. Unlike the livescan devices at custody centres, there is no requirement for the subject to have to roll or rotate their fingers to obtain a capture. Subjects should be given clear verbal instructions on how and where to place their index fingers on the scan screen, thereby reducing the need for the officer to make physical contact. However, officers are reminded to adopt safe working practices when dealing with any member of the public who poses a risk from infectious disease. If the subject has any kind of injury that has resulted in bleeding, or if they should their hands be contaminated with any other body fluids, the use of first-aid alcohol wipes should be considered for the subject prior to providing their fingerprints. Furthermore, after providing fingerprints, the scan screen should also be cleaned with an anti-bacterial wipe or similar hard surface cleaner. 9.4 Suspected Improvised Explosive Devices (IEDs) The Device transmits using a 3G mobile phone signal and therefore, like all transmitting devices, poses a potential risk if the vehicle is used to attend an incident involving suspected IED s. Logging off the system is not sufficient, as the system will still attempt to make connections to the mobile network unless it is powered off. For this reason, the Device must be powered off completely and not brought any closer than 50 metres of a suspected device. 9.5 Display Screen Equipment Regulations (DSE) These regulations are intended for fixed workstations in police buildings, but DSE good practice should be considered when using MobileID Devices Avoid extended use of the device. Interaction should be limited to 15 minutes at a time. Document Name: Mobile ID Manual of Guidance Page 14

21 9.5.2 Where fitted, adjust screen brightness to suit ambient lighting conditions Users should report adverse effects of use of the device to their supervisor immediately Users that require to wear spectacles specifically for display screen work should wear these for use with Mobile ID Devices. 9.6 Distractions to the Driver Drivers of police vehicles are bound by individual responsibilities to comply with road traffic legislation, force policy and procedure for the safe use of vehicles. This will include that the use of any ancillary equipment fitted to the vehicle does not distract that officer from the primary responsibility of maintaining full and proper control of that vehicle. 9.7 Electromagnetic Emissions As the device utilises mobile phone transmission technology, it emits electromagnetic radiation whilst in use. Independent testing has been conducted that ensures that the level of these emissions are within recommended limits, and does not pose a risk to the health of the users. However, due to the signals being transmitted, there is a risk of these signals causing interference with sensitive equipment. Such equipment includes but is not limited to: Speed Enforcement devices Medical care equipment (Hospital Heart Monitors etc) Roadside and station substantive breath test devices Fuel Filling station pumps. The device should be powered off when in the proximity of these or similar items of equipment. Document Name: Mobile ID Manual of Guidance Page 15

22 10 LEGAL CONSIDERATIONS AND REQUIREMENTS Outside of the legal procedures governed by PACE as laid out in section 4.1 above, all MobileID Device users must be aware of their responsibilities in law in relation to the use of the devices. These include, but are not limited to, the following items: 10.1 Data Protection Act 1988 The Data Protection Act 1988 (DPA) has eight Principles with which a user must comply: 1. Personal Data shall be processed fairly and lawfully and shall not be processed unless scheduled conditions are met; 2. Personal Data shall be held for a specified, lawful, notified purpose(s) and not further processed in a manner incompatible with the notified purpose(s); 3. Personal Data shall be adequate, relevant and kept up to date; 4. Personal Data shall be accurate and kept up to date; 5. Personal Data shall be kept no longer than is necessary; 6. Personal Data shall be processed in accordance with the Data Subject s rights; 7. Personal Data shall be kept secure and have declared security and procedural measures against unauthorised access, accidental or deliberate loss, damage or alteration; 8. Personal Data shall not be transferred outside the EU unless the destination is approved by the Information Commissioner. Section 55 of the DPA states that it is an offence to unlawfully obtain or disclose personal data, or to procure the disclosure of it to another person, without the consent of the organization responsible for that information. It is also an offence to sell, or offer to sell, personal data after it has been unlawfully obtained, disclosed, or procured. (Therefore, it is an offence to obtain data or to obtain and disclose data without authority, and it is an offence to offer to sell or to actually sell data). Document Name: Mobile ID Manual of Guidance Page 16

23 10.2 Computer Misuse Act From 1st September 1990, three offences were created under the Computer Misuse Act: Unauthorised access to computer material Unauthorised access with intent to commit or facilitate commission of further offences Unauthorised modification of computer material These offences cater for instances where users allow other persons to use their log in details, or where users access Mobile ID Devices that have been logged on previously by someone else The Representation of the People (England and Wales) (Amendment) Regulations 2002 Regulation 109(1) in relation to the full and un-edited information contained within the Electoral Roll (or Voters Index) applies to the following: (a) any police force in Great Britain; (b) the Police Service of Northern Ireland and the Police Service of Northern Ireland (Reserve); (c) the National Criminal Intelligence Service; (d) the National Crime Squad; (e) the National Policing Improvement Agency; and (f) any body of constables established under an Act of Parliament. (2) For the purposes of regulation 102(1) above the relevant part of the documents listed in that provision is the whole of them. (3) No person serving whether as a constable, officer or employee in any of the forces and organisations to which this regulation applies may - (a) supply a copy of the full register to any person, (b) disclose any information contained in it (that is not contained in the edited register), or (c) make use of any such information, otherwise than for the purpose of the prevention and detection of crime and the enforcement of the criminal law (whether in England and Wales or elsewhere) Section 3 of the Road Traffic Act 1988 This creates offences of driving without due care and attention and driving without reasonable consideration on a road or public place. Also be aware of other useful offences in such circumstances, referred to at the end of this document. Document Name: Mobile ID Manual of Guidance Page 17

24 If a person drives a mechanically propelled vehicle on a road or other public place without due care and attention, or without reasonable consideration for other persons using the road or public place, he is guilty of an offence 10.5 Regulation 104 of the Road Vehicles (Construction and Use) Regulations 1986 This regulation creates an offence of the driver of a motor vehicle not being in a position to have proper control of the vehicle or a full view of the road and traffic ahead. No person shall drive or cause or permit any other person to drive, a motor vehicle on a road if he is in such a position that he cannot have proper control of the vehicle or have a full view of the road and traffic ahead 10.6 Force Policy and Procedures (FPPs) The following Policies (and their associated Procedures) are from the Surrey Force Policy and Procedure Library and have been identified as having a likely bearing on the use of Mobile ID Devices. It must be stressed that this Manual of Guidance is NOT a force policy document, but is intended to be used as a reference guide to the use of the equipment installed. Although careful attention has been paid to ensure that conflicts do not exist between this Manual and current Force Policies, in the event of a contradiction or difference being found, it must be held that the Force Policy will take primacy. If during routine use of the Device a conflict is found with the above policies, or if users should have any comments or suggestions for additional policies that are not shown here, they should forward any comments via to: Document Name: Mobile ID Manual of Guidance Page 18