Dear Heidi

We thank you for your questions and the opportunity to respond.

While every effort has been made to provide you with sufficient detail in response to your
questions, please understand that the nature and purpose of what Vumacam does is
dependent on stringent security around our systems.

We have therefore responded in so far as we can to ensure we do not compromise safety

protocols and any commercially sensitive or privacy bound areas.

A general statement from us follows and more detailed answers to your questions are
below.

Since Vumacam’s inception, privacy has been as important a consideration as our core
business purpose - to aid private and public institutions in crime prevention, detection, and
apprehension in South Africa. Due to the nature of what Vumacam does, we have high
levels of data security, privacy, vetting, training, log-ins with VPN for traceability, and
systems in place to audit activity using our platforms.

Vumacam has taken thorough steps to ensure POPIA compliance. Our correspondence with
the Information Regulator earlier in the year indicated that we would have the opportunity
to engage in months to come. In the interim, we have taken all practical steps – following
advice from both legal and data privacy experts – to ensure unwavering POPIA compliance.

Over and above the extensive measures implemented, and the training our team has
received, and ongoing training from time to time, we are developing a POPIA e-learning
platform for all our private security clients which will serve as a prerequisite, in addition to
PSIRA registration, for all operators who need to gain access to our platforms.

Vumacam provides technology and private security companies who make use of the
technology through trained operators. Neighbourhood watches and CPFs do not have direct
access to our systems. They need to conduct any requests through their private, contracted
security company and these companies are PSIRA registered. Both CPF/neighbourhood
watches and private security companies sign POPIA-centric agreements with Vumacam and
will undergo training via our electronic platform.

We take our own data security very seriously. All security operators have to have criminal
conduct checks to be PSIRA-registered and must be POPIA trained. Our system reports all
search requests and any requests that fall outside the bounds of strict protocols are flagged.

Our technology ensures that the majority of footage remains unseen and footage involving a
criminal or suspected criminal incident or emergency situation is viewed (and with rigorous
processes in place to limit access to footage). Cameras only capture what is in the public
domain and only with the purpose of aiding private and public institutions in crime
prevention, detection and apprehension in South Africa.
Vumacam technology uses artificial intelligence (AI) to flag “unusual incidences”, for example,
someone being attacked, a gun, a knife, someone falling, breaking a car window and so forth.
We do not use facial recognition technology and we do not have the assurance or confidence
that the tech is advanced or accurate enough to validate its ethical usage by users on our
platform. The system does not track individuals.

Our AI monitors behaviour and is not designed to recognise or track and trace or identify an
individual. Bias is thus not a consideration or risk. The system could scour for an item of
identifiable clothing from the footage available, for example, to find a missing child based on
a description of clothing, as one of our customers was recently successful in doing.

The cameras and tech cannot trace the specific movements of an individual or vehicle. This is
not their purpose or function, and it would not be a successful means for any nefarious
individual to attempt to follow a person’s movements, not only because they would soon be
caught in our environment but also because the system, our security and our tech alone
would provide very little value for a criminal trying to trace an individual.

Our Licence Plate Recognition (LPR) cameras detect vehicle licence plate numbers that have
been involved (or are suspected to be involved) in criminal activity. While security companies
can search for a vehicle in urgent and real-time situations using two-factor authentication and
providing valid reasons for their search, they may only search for footage of a vehicle
retrospectively with strict protocols in place and require a valid case number to download
footage.

While the ability for criminals to unlawfully manipulate any system to their advantage will
always exist, we believe that our stringent processes and world-class technology prevent
this as far as possible and Vumacam will always seek new, innovative ways to protect
against unlawful activity.

Our LPR technology would flag a number plate only if a vehicle has been involved in suspected
criminal activity and a vehicle would only be detected if it drove past one of our cameras.

We comply not only with POPI but also have always looked to international GDPR as
guidance prior to POPIA being promulgated.. Privacy is crucial and we take the responsibility
of what we do very seriously.

Our cameras are very much in the public interest where South Africans’ right to safety is
challenged on a daily basis. We serve the public – directly and through our clients. There have
been thousands of successes in the use of Vumacam to stop, prevent and investigate crimes
that cost lives, negatively impact the economy and impact the safety of South Africans.

Please refer to the more detailed notes below on specific questions.

Question 1
1.1 In 2019, Vumacam said that its camera rental fee per month was R730 per camera.
How much is Vumacam’s rental per camera per month currently?

Comment/Response
Our pricing is specific to each client and dependant on many factors
such as the number of cameras required for a specific area of
surveillance, camera type and location. Clients who rent larger
numbers of cameras benefit from economies of scale on a per-camera
cost.

1.2 Does this rental include both the LPR and the overhead camera? Or are the LPR and the
overhead cameras charged separately? If so, what are the costs for each?

Comment/Response
They are rented per requirement for an area and would be rented at a
cost per type of camera. Not all poles have both types of cameras on
them.

1.3 According to the presentation, as of January 2021, the company had

2856 poles in the ground, and 4366 cameras. Uptime was at 98.10%.

If these figures have changed, can you please provide the updated figures?

Comment/Response
While uptime is consistent as an average over a period of time, the
number of poles and cameras might change daily due to new requests
for cameras. This is updated on our website home page on a monthly
basis.

1.4 How many LPR cameras are there currently, in total?

Comment/Response
2262

1.5 How many overhead cameras are there currently, in total?

Comment/Response
2925

1.6 I understand Vumacam has built additional storage space for data on its own premises.
Has this been completed?

Comment/Response
Due to strict safety, security and privacy protocols in place at
Vumacam, we do not disclose where data is stored.

1.7 Are there any other storage facilities used by Vumacam?

 Comment/Response
Due to strict safety, security and privacy protocols in place at
Vumacam, this information is confidential.

1.8 How much data can the system store at any one time (taking into account the additional
storage space and space at Teraco combined? (i.e. What is Vumacam's maximum monthly
storage capacity at present?)

Comment/Response
While we once again must reiterate the importance of confidentiality
to ensure that we maintain high levels of security on our systems (and
as such cannot divulge specific details), we have sufficient capacity to
meet the requisite 30 days of storage offered to clients.

1.9 On average, how many petabytes of footage does Vumacam's system store per month?

Comment/Response
Again, we must reiterate the importance of confidentiality to ensure
that we maintain high levels of security on our systems (and as such
cannot divulge specific details), however, we have sufficient capacity to
meet our obligations to our clients, and to retain any critical evidence
that might need to be drawn from the system to prosecute or arrest
criminals or to provide evidence in a criminal investigation.

1.10 On average, how many registration number scans (including scans of the same
number) are stored in Vumacam's system per month?

Comment/Response
This number will fluctuate based on various factors. Only vehicles of
interest (VOI) that have been logged in the system following strict
protocols would flag on the system and generate an alert. The rest of
these scans are flushed from the system after the requisite period of
time unless placed in evidence lock for further investigation.

1.11 On average, how many registration numbers (excluding repeated scans of the same
number) are stored in Vumacam's system per month?

Comment/Response
This number will naturally fluctuate based on a number of factors. We
do not keep a record of unique scans as our systems are not primed to
filter this level of detail for any reason.

1.12 During an interview last year with TechCentral's Duncan McCleod, Mr Croock said that
Vumacam had 40 security companies that had subscribed to its service. In the presentation,
Vumacam states that it has 50 clients. How many clients does Vumacam have now? Can you
please provide a breakdown, according to figures, of the type of clients (Security companies,
vehicle tracking companies, residents' associations, etc.) ?

Comment/Response
In the interests of client privacy and security, we cannot provide a
specific breakdown, however our security clients use our cameras and
technology platforms only for the purpose of preventing and/or
fighting crime.

Question 2:

Vumacam's website states: "The playback tab will allow you to review, and extract
footage. The retrieval process strictly adheres to privacy and data protection
regulations. All footage is stored for 14 days in the default contract, or more if the security
company requires so (impacts pricing)."

2.1 Is storage time also applicable to LPR data?

Comment/Response
Yes it is an

2.2 What is the price difference for a client wishing to have access to footage for 30 days, as
opposed to 14 days?
Comment/Response
This is dependent on the size of a specific contract as economies of
scale are in play and is quoted per client.

2.3 What is the price difference for a client wishing to have access to LPR data for 30 days,
as opposed to 14 days?
Comment/Response
This is dependent on the size of a specific contract as economies of
scale are in play and is quoted per client.

Question 3:

According to the presentation, Vumacam's system has 3463 LPR hits per minute. The same
document states that Vumacam has 50 clients. If there are 50 monitoring rooms, it means
each one receives (on average) 69 alerts a minute. That’s more than one alert per second.
This means they are constantly receiving alerts. How can they respond to such an influx of
alerts? If I am misinterpreting this statistic, please can you explain it to me in very simple
terms so that I can in turn clarify it for the reader.

Comment/Response
 Yes this is a misinterpretation. LPR hits and VOI hits are very different.
LPR hits are the number of cars passing an LPR camera. These are not
alerting into any control room.
They are queried against the SAPS Unicode and vehicles of interest
(VOI) databases. If any are VOI then those alerts are sent through to
control rooms to investigate.

Only vehicles of interest (VOI) that have been logged in the system
following strict protocols would be flagged, reviewed and escalated.

Codes used on the SAPS Unicode database indicate the crimes that
each VOI is suspected of being involved in and security teams can
prioritise and manage their responses accordingly.

Question 4

On Vumacam’s website, it explicitly states that the system cannot track people. It says:

However, the presentation shows that Vumacam can track any vehicle over extended
periods should they so desire – even if its registration number is not in SAPS’s or any other
vehicle-of-interest database.

The presentation shows details of an event called the “Ferndale Incident”. It took place on
25 November 2019. It shows how the movements of a vehicle could be mapped for the
period of a month. I understand this is possible because Vumacam stores ALL the vehicle
registration numbers scanned by its system for at least a month (i.e., registration numbers
of the cars associated with crime, and the cars belonging to citizens not involved in crime,
are all recorded and stored). The LPR scans are time-stamped and the cameras are fixed.
This means it is possible to track any vehicle by using analytics, as long as its registration
number is provided to Vumacam. In the presentation, two searches of vehicle registration
numbers were conducted, and neither of these vehicle registration numbers were in any of
the vehicle-of-interest databases (belonging either to SAPS or any other security
companies). Thus, it is technically possible to map (in other words, track) any vehicle's
movements. In other words, vehicles that are not associated with crimes or "incidents", can
be tracked. It also means Vumacam can track anyone’s car in real time.

Mr Croock has stated that an individual cannot be identified through their vehicle
registration number, since Vumacam’s system is not linked to eNatis. However, eNatis is not
the only way to link an individual to their registration number. Vumacam’s system can map
someone’s movements in a way similar to a GPS tracking system (as the presentation and
the "Ferndale Incident" clearly show). With additional investigation (in the manner that
police or private investigators may do it) it is possible to collect more information, and find
out where a person lives, works, socialises, etc. Ultimately, the LPR system provides
actionable intelligence that, when augmented by additional intelligence gathered through
other investigative methods, can be used to identify the individual to whom the registration
number belongs. This is similar to how police operate when they track a suspect (who they
have not yet positively identified) via cell phone tower location data that they obtain from
cell phone companies. (Because so many cell phones are registered to false or stolen
identities, police must at times make due with only a phone number to do tracking.) If you
can physically locate an individual, it is possible to identify them. Whereas the police need a
warrant to get cell phone tower location data, which is not as accurate as Vumacam’s LPR
data, private security companies only need to pay Vumacam for LPR data to use the tracking
system. The police need a court order if they approach Vumacam for LPR data.

There are serious factual inaccuracies in the above statements which must be made clear:

1) Neither a warrant, court order nor case number is required to receive a notification
on our system when a VOI passes a camera in a point in time. This is because no
personal data is being revealed and vehicle registration numbers exist for the
purpose of making vehicles identifiable (and particularly to law enforcement) on
public roads. This would also no different to police creating any other “look out”
alert for a VOI via any other channel.
2) Vumacam cannot track a vehicle in real time – this is impossible. We can only
provide footage and the location of a vehicle IF it passes one of our cameras. In the
case of a crime in progress, a VOI passing one of our cameras will flag IF it passes one
of our LPR cameras and this information can be sent to security companies or SAPS
who might be in pursuit of a suspect.
3) Authorised users at security companies can do a live search using two-factor
authentication and motivation. This would apply, for example, in the case of
someone being hijacked or kidnapped where urgent response is needed. This is
under strict protocols and our system ensures that any individual doing so without
the requisite protocols in place will be flagged.
4) It is important to note that clients cannot download footage themselves, only
Vumacam is able to once all pre-requisites have been met. A case number is
required for any footage that is downloaded as evidence.
5) Vumacam DOES NOT use or analyse this non-personal and anonymised data – we
provide the data to our clients and the police for use in fighting crime. Vumacam
does not tie this data to any personal information.
6) While the police or security companies may use our anonymised data alongside
other investigative strategies or techniques, this is in line with any investigative
activities that bring criminals to book. Our cameras are effectively reliable witnesses
and can only record a number plate as much as an individual might write it down or
take a picture of it with a cellphone camera.

Where there is reasonable suspicion, footage allows for further steps to be taken - either to
arrest a suspect or suspects and conversely to absolve a suspect where criminal activity
might not have taken place.

My questions are as follows:

5.1 Can security companies construct maps of vehicle movements retrospectively, as was
demonstrated in the presentation, or can only Vumacam perform this function?

Comment/Response
Authorised users can search for a specific plate under strict protocols.
The system displays the last 10 chronological locations on where a VOI
was alerted when passing a camera in a map view. This allows for
supportive evidence in the case of a crime being committed

5.2 If security companies can perform this function, does Vumacam keep track of every time
a security company employs the function?

Comment/Response
Yes – every search is audited and systems flag any search that falls
outside of the bounds of our protocols. Reports are also sent to the
client’s compliance officer.

5.3 On average each month, how often do security companies map/track vehicle
movements a) retrospectively and b) in real-time?

Comment/Response
Vumacam provides cameras and technology platforms that flag VOI and
alert security companies to their existence. We do not use the data
ourselves or track vehicle movements. Again, the system cannot track a
vehicle – it can only provide an alert when and if a vehicle passes one of
our cameras. Vumacam does not use or analyse this non-personal and
anonymised data – we provide the data to our clients for use in fighting
crime.

We cannot disclose the number of searches conducted by our clients as

this information is private, secure client information. It varies between
clients based on their usage and is subject to the protocols previously
described.

5.4 On average each month, how often does Vumacam map/track vehicle movements a)
retrospectively and b) in real-time?

Comment/Response
Vumacam provides cameras and technology platforms that flag VOI and
alert security companies to their existence. We do not use the data
ourselves or map vehicle movements. Again, the system cannot track a
vehicle – it can only provide an alert when and if a vehicle passes one of
our cameras. Vumacam does not use or analyse this non-personal and
 anonymised data – we provide the data to our clients for use in fighting
crime.

5.5 Regardless of whether such mapping and tracking of vehicle movements are carried out
by Vumacam or security companies, how many of these maps are constructed, on a monthly
basis on average, for the movements of vehicles that are NOT in any of the vehicle of
interest databases?
Comment/Response
Again, Vumacam systems cannot be used to track a vehicle – this is
impossible. Vumacam does not provide any mapping. The “map” you
refer to is a security company screenshot of where a VOI passed
Vumacams. While security companies may be able to identify where a
VOI went past cameras, our system will flag any unauthorised use of
the system.

5.6 How does Vumacam ensure that such maps are generated for crime-related events
only?
Comment/Response
Again, we do not create maps. That said, should security companies
conduct searches (and therefor see when a VOI passed one of our
cameras), authorised users must do so via two-factor authentication,
capture the reason for the search each time a search is conducted and
our audit system would flag suspicious use should there ever be any.

5.7 What does Vumacam consider to be a 'verified incident'. Please provide as much
information as possible.
Comment/Response
An incident reported by a member of the public, reported by security or
police or flagged on our system as a crime, or potential crime incident.

5.8 Why does Vumacam say that its system does not track people, when in actual fact it
does?

Comment/Response
This is a false statement and wholly untrue. Vumacam systems do not
track people and do not have the ability to do so. They have the
capability to plot the locations of the cameras that identified a number
plate. They do not and cannot track a person. They also cannot identify
a person via a number plate or tie any vehicle or individual to any
personal data.

Data is totally anonymised and is not of a personal nature.

5.9 The presentation talks about two bravo males. What does the word 'bravo' refer to?
 Comment/Response
The presentation captures dialogue and input from a security partner
and not Vumacam.

We therefore cannot comment on the specifics of this descriptor in its

specific context but can provide general context on the use of “Bravo”.
This is the code for the letter “B” in the International Radiotelephony
Spelling Alphabet or NATO phonetic alphabet. This was created so that
the names for letters and numbers would be distinct enough to be
easily understood by those who exchanged voice messages by radio or
telephone, regardless of language differences or the quality of the
connection.

In the case of identifying criminal suspects, descriptions of clothes,

shoes, height, and race are used by police, military, private security and
other organisations. ‘Whiskey” male or female refers to a white
individual and “Bravo” male or female to a black individual.

Question 6

It is possible to use analytics to search for vehicles that passed a specific camera during a
specific time frame.

6.1 How many such searches are conducted, in total, by all Vumacam’s clients during a
month, on average?

Comment/Response
This is private, secure client information that cannot be disclosed.

6.2 How many such searches are conducted, in total, by Vumacam in a month, on average?

Comment/Response
Searches are conducted only by clients authorised to do so. Vumacam
only conducts an average of 10 searches per month for testing
purposes only (validating software releases and system response
times).

Question 7

It is my understanding from Vumacam’s policy and marketing material that the police can
only get vehicle tracking information from Vumacam’s LPR system if they approach the
company with a court order. However, in September last year, security company
AISurveillance published an article explaining how the Linden SAPS had provided them with
a number of registration numbers, which AISurveillance then entered into the AISurveillance
vehicle-of-interest database. Using Vumacam’s LPR cameras, AISurveillance was able to find
these vehicles for SAPS. It is unclear to me why SAPS did not enter these vehicle registration
numbers into their own Unicode database and approach Vumacam with a court order. If
SAPS approaches private companies to do LPR surveillance for them, this provides a way for
the police to avoid getting a court order.
7.1 Would you care to comment on the above scenario?

Comment/Response
It must be again emphasised that Vumacam systems cannot track a
vehicle and don’t have vehicle tracking systems. A camera can flag
when a VOI passes a camera retrospectively and creates an alert in real
time. Neither a case number nor court order is required to search for a
vehicle of interest (VOI) as licence plates exist to identify vehicles in the
public domain. Further, SAPS does not need a court order to enter a
VOI in Unicode. In this instance, the SAPS request was to ensure
priority was given to notifying SAPS when and if the VOI was flagged on
the system in attempt to apprehend the suspects who were involved in
multiple serious crimes.

7.2 How many other vehicle-of-interest databases is Vumacam's LPR system linked to?

Comment/Response
This number is based on current client base and partner agreements.
We cannot reveal this information for both security reasons and due to
non-disclosure and privacy agreements in place with our clients.

7.3 In total, how many vehicles of interest are contained, collectively, in these private
databases currently?

Comment/Response
We do not reveal this information for both security reasons and due to
non-disclosure and privacy agreements in place with our clients.

7.4 In order to prevent misuse, does Vumacam at all control the process whereby additional
vehicles of interest are added to the private security databases? If so, please provide
details.
Comment/Response
Vumacam cannot control how or what happens on private security
databases. Our vetted clients are however all PSIRA registered and
once using Vumacam systems, must provide validated reasons and/or
case numbers for conducting searches. They are subject to our usage
policy and must use two-factor authentication. In other words, if a
private security company was conducting a search without a valid
 reason or a case number, this would be flagged and the individual
conducting this search would be identified.

7.5 How can Vumacam guarantee that the registration numbers added to the databases of
private security companies were in fact involved in criminal or suspicious activities?

Comment/Response
We do not manage these databases and cannot guarantee that they
are absolutely correct. We do, however, believe that companies that
manage these databases hold themselves to high standards of ethics
and data credibility. Nonetheless, Vumacam requires all security
companies to adhere to our protocols (mentioned earlier) to conduct a
search if a vehicle is in a VOI database.

7.6 How can Vumacam guarantee that the registration numbers added to the databases of
private security companies are not provided by SAPS, giving them an avenue to conduct
surveillance without a warrant?
Comment/Response
We do not manage these databases, however, a warrant is not required
to view footage captured in the public domain. Vumacam does not and
cannot provide ongoing surveillance on any one vehicle or individual.
Vumacam would only be able to flag a VOI if and when it passed an LPR
camera or provide footage of a crime in progress should this have been
captured by a camera.

SAPS is free to view all footage via our security partners in their
important work to combat crime and take criminals off our streets. The
power of technology and public-private partnerships in crime fighting is
vital in the South African context where crime impacts innocent people
daily.

Question 8

Vumacam makes several commitments in its privacy policy and on its website stating that it
ensures that the companies do not misuse its system in any way. There are, however,
various tools provided in the Milestone VMS (for instance, audit logs) to allow Vumacam to
oversee with more precision how the companies use their system. Milestone also has
limitations; for instance, audit logs can slow down the system, and keeping less detailed logs
can help solve this issue. Vumacam does not commit to using any specific features or
parameters in Milestone to monitor security companies' use of its system.

8.1 Do you use Milestone, or any other software, to electronically monitor how security
companies are using your system? (For instance, who logs on for what periods of time,
searches of footage or the LPR records, footage replays, etc.) Please provide as much detail
as possible.
 Comment/Response
For security reasons, we cannot share specific details of software or
detailed processes.

Our live feed operates optimally on black-screen technology whereby

operators only have a view when and if an alert is received due to
unusual or suspected criminal activity.

The system only has the ability to flag the movement of a vehicle past
our static cameras when and if its license plate has been linked to
criminal or suspected criminal activity.

For investigating past incidents or crimes, Vumacam’s search

functionality has to be engaged.

Due to the nature of what Vumacam does, we have high levels of data
security, privacy, vetting, training, log-ins with VPN for traceability, and
systems in place to monitor suspicious use of the system.

Vumacam has taken a number of additional measures to ensure non-

susceptibility to misuse, as far as possible, including:

1. Multi-factor authentication (2FA) for the limited and vetted

users who have access to our search capability.
2. Increased regularity and stringency of search function audits
which over and above security company review are also audited
by the Vumacam CIO for any irregular activity.
3. Limited and vetted users of our search function may not engage
the system for lengthy periods of time and would have to log in
to separate search sessions should they require to do so for any
investigation. This would be flagged as suspicious.

In addition, the search functionality is audited and requires a valid

reason and case number/and or court order for limited operators to
conduct a long-term search.

8.2 Is data erasure of both overhead camera footage and LPR records scheduled
automatically? If not, how does Vumacam ensure that its footage and LPR records are not
kept for too long?
Comment/Response
 In both cases, footage is purged from the system automatically unless
placed in evidence lock. This is for the purpose of using footage as
evidence in a crime and it is only accessible by investigating and vetted
parties.

9. Vumacam's tracking capability is comparable to having a GPS device attached to one's

vehicle. However, whereas one can choose not to have a GPS device attached to your car, or
whereas one can leave your phone at home to avoid being tracked, it is impossible to
escape Vumacam's cameras, and the public is not given an option to opt out. Would you
care to comment on this?
Comment/Response
This is an entirely false statement. Vumacam technology cannot track
vehicles and does not function anything like a GPS device. Vumacam
triggers an alert when a VOI passes a camera location.

It does not track vehicles in motion or individuals. The majority of

vehicles passing an LPR camera are not flagged at all, as the majority of
vehicles are not in the VOI database.

A GPS moves with the vehicle. The primary purpose of a GPS is to

inform the user of their exact current location. Modern GPS units can
pinpoint location to an accuracy of 7.5m or better. Vumacam has the
equivalent of 1 camera per 8 km2 in Gauteng or nearly 1 000 times less
accurate than a GPS.

The Global Positioning System is not a tracking system. By the same

token, the LPR cameras are not a tracking system but a mechanism to
collect data regarding publicly visible license plates to identify vehicles
of interest with the purpose of combatting crime.

There is no focus on law-abiding citizens and no ability to track a

vehicle or an individual.

There is no reason to “opt out” as no member of the public is being

tracked or opted into anything against their will. Cameras merely
provide footage of number plate in space and time. While this is a
powerful tool in investigating and assisting in preventing crime, it is
futile for any other purpose.

10. Have you considered using software to mask number plates that are not contained in
any vehicle-of-interest databases? If not, why not? If so, do you know if or when you will
start employing such software?
Comment/Response
We are investigating obfuscation technology for our LPR systems, but
this technology is both expensive and frequently inaccurate. Given the
public nature of a license plate, obfuscation during day-to-day
 operations is not significantly beneficial. Content released publicly or
for evidentiary purposes will have irrelevant information obfuscated in
future.

11. Vumacam's surveillance capability in terms of vehicle tracking is on par, and even far
more extensive than, current government LPR systems. Vumacam is also capable of tracking
people, via their vehicles, much more accurately than the police or intelligence services can
track people via their cell phone's tower data. Despite this, there is no law (such as, for
instance, section 205 of the Criminal Procedures Act, or RICA) regulating Vumacam's
actions. There is also no independent oversight of Vumacam's LPR system. At the same
time, the public is entirely reliant of Vumacam to act ethically and responsibly. Ultimately,
Vumacam’s loyalty lies with the interests of their paying clients. These interests are not
necessarily aligned to the public interest. Yet, Vumacam must police itself and its clients to
make sure that its tracking system isn’t abused. Would you care to comment on this
potential conflict of interest?

Comment/Response
This is factually incorrect. Again, it must be emphasised that Vumacam
cannot track vehicles or people.

The primary focus of the LPR system is not to track individuals or

vehicles. It is to observe and flag criminal or suspicious behaviour and
then alert security services and the police to the presence of a vehicle
of interest (not a person of interest) or a crime or suspected crime in
progress. They can assist in helping to intercept vehicles that have been
involved in criminal activity, some of which are serious crimes such as
robberies, attempted murders and hijackings in progress. They flag
vehicles with stolen number plates and can flag when vehicles
identified in crimes have moved into a location. Unfortunately it is
impossible to attribute crime prevention to a number, but our
customers can attest to their own experiences in the areas in which
they operate.

The claim that LPR cameras are much more accurate than tracking via
cell-phone towers is entirely incorrect.

The cellular networks’ ability to triangulate the location of a device in

real-time is incomparable to a vehicle being flagged when it passes
static cameras in various locations.

The statement also refers to “regulating Vumacam’s actions” - we do

not take action and we do not track anyone. We provide information
that is in the public domain to vetted and approved clients for them to
use in an appropriate manner.
Vumacam cannot stress enough that our platform presents data in a
simplified efficient manner but does not make any recommendations, it
is still up to trained vetted security operators to validate that a number
plate has been read 100% by the camera and that the VOI is accurate
and or the suspicious activity requires any response. Vumacam's focus
is on ensuring high quality service levels and auditability to the private
security industry which enables them to perform their services better.

We comply with POPI which is enforced by the Information Regulator.

Privacy is crucial and we take the responsibility for what we do very
seriously. Other than the Constitution of the Republic of South Africa
which provides us with a legitimate right to privacy (section 14) and a
right to freedom and security of a person (section 12), we also have
POPIA which governs us, PAIA, PSIRA, common law, and we have every
functioning court and gavel holding us accountable.

Our cameras are very much in the public interest where South Africans
right to safety is challenged on a daily basis. We serve the public –
directly and through our clients. There has never been an incident of
misuse but certainly hundreds of successes through the use of
Vumacam as a tool to stop, prevent and investigate crimes that cost
lives, the economy and the safety of South Africans.