Surveillance Camera Commissioner hits out at merger proposals and reports on certification progress

The Surveillance Camera Commissioner has set out his differences with government on the proposal to absorb his statutory functions under the Information Commissioner, and on the rejection of his attempts to include in the Surveillance Camera Code of Practice ethical considerations authorities need to consider.

Professor Fraser Sampson

Writing in his Annual Report January 2020-March 2021 on the temptation to merge the functions of the various commissioners, the Commissioner, Professor Fraser Sampson, said he would urge careful consideration of the “beguiling simplicity of generalising this area as merely involving matters of data protection”. He said the “abhorrent facts” of a case of the recoding of images in a hospital mortuary showed very starkly how intrusions into the most private aspects of people’s lives cannot always be reduced to a matter of “data rights”.

He said that as we approach a future in which public safety increasingly relies on data being pooled from sources such as social media, driving licenses, police databases and dark data, “we need as a minimum, a single set of clear principles by which those operating surveillance camera systems will be held to account, transparently and auditably”. The acid test will be whether we know that camera systems are only being used for legitimate, authorised purposes in a way that communities are prepared to support.

In early 2020, the National Surveillance Camera Strategy was refreshed with new objectives. These remain relevant for the period 2020-2023 but will be kept under regular review in light of changing legislation, evolving technologies and increased levels of public awareness and concern.

Standards and certification

The objective for this strand of the National Surveillance Camera Strategy is to produce guidance and requirements – based on agreed standards – for manufacturers, consultants, installers and monitoring centres. Those standards are intended to ensure a quality management approach, from the capture of an image through to images being passed onto the police, and all points in between.

Two new third-party certification schemes are due to be launched in 2022. According to the Commissioner, the certification scheme for service providers – those who install, integrate and design surveillance camera systems – will mean that end users will have systems that fully meet their needs, the police will have access to better video evidence, and the public will have more reassurance over the integrity of those systems. The scheme for monitoring centres – both in-house and contracted out – is designed to ensure that they operate to relevant British and international standards.

Civil engagement

Public engagement initiatives have included a stakeholder workshop, a survey of local authorities, public lectures and panel sessions, activities in the media and the first Surveillance Camera Day in 2019, which drew attention to a national conversation about surveillance systems. The next Surveillance Camera Day was scheduled to take place at IFSEC International in June 2020, but was postponed until 2022 due to Covid-19 restrictions.

Planned activities, such as presentations at schools and parliamentary events, had to be abandoned because of Covid-19 and a congested parliamentary timetable due to Brexit and the pandemic. These activities, the report says, can readily be revisited and form part of a broader engagement plan.

Policing

Police forces are ‘relevant authorities’ so must consider the 12 guiding principles of the Surveillance Camera Code of Practice when using overt surveillance camera systems in public spaces.

Surveys have shown that the percentage of forces using CCTV, drone technology and body-worn video has increased, and that levels of compliance have also increased. But the percentage of forces using a self-assessment tool (SAT) to demonstrate compliance has fallen, or at best not changed. Professor Sampson said: “I would like to work with police forces to drive up completion rates… Although there is no legal obligation to complete a SAT, it would assist forces in identifying areas for improvement and consequently increase their compliance levels further.”

Local authorities

In a survey of local authorities, 184 of them responded (around half).

Only one local authority said it was not using any camera systems, and there were no reports of any local authority using facial recognition technology.

It was reported that more than 80,000 cameras were in operation across 6,000 systems, the majority of which are CCTV cameras, but with dash cams and body worn cameras also in use. The largest number of systems were operating in and on vehicles (1,240), followed by municipal buildings (931), housing (796) and town centres (370). Housing accounts for the largest number of cameras (16,901), followed by town centres (14,702), municipal buildings (12,051) and vehicles (8,842).

Other survey findings are:

• Most local authorities work in partnership with police, with footage from their systems being used in criminal investigations and to assist with live incidents
• Half the authorities said they work in partnership with other local authorities
• Many worked in partnership with others, such as business improvement districts, housing associations and professional football clubs, hospitals and transport providers
• Over a quarter of local authorities have cameras operated on their behalf by a third party.

Around 60% of respondents are reviewing more than 250 pieces of footage a year, with over a quarter carrying out more than 1,000 reviews annually. Across the board, it is estimated that there are 184,875 reviews and 63,500 pieces of media submitted to police annually.

Surveillance Camera Code of Practice

The Surveillance Camera Code of Practice applies to systems covering public spaces operated by ‘relevant bodies’, which are designated by the government. At present, these are confined to local authorities and the police, so the list does not include some of the largest operators of systems nor the government itself.

“I have repeated my predecessor’s call,” said Professor Sampson, “and that of many other consultees, for other organisations to be added to the list of ‘relevant authorities’ defined under the Act, to include the ‘volume’ operators of surveillance cameras in public space such as hospitals, education partnerships, transport providers and government departments. I have not succeeded in persuading ministers to extend this list.” He added that he continues to raise this with the Home Office, and looks forward to seeing the revised Code of Practice laid in parliament.

The Commissioner’s report states that for any revised list not to include government departments in the future would “require a very compelling case”. He encourages other organisations to adopt the principles of the code on a voluntary basis, and to apply for the Commissioner’s certification mark, which would enable them to demonstrate that their systems are proportionate, effective, justified and transparent. Organisations such as Marks & Spencer, Britannia Parking Group, National Car Parks and Walsall Housing Group, have recently acquired certification against the Code.

Commenting in response to the government’s consultation on the absorption of the Surveillance Camera Commissioner’s statutory functions by the Information Commissioner’s Office, Professor Sampson said: “We now have a once-in-this-generation opportunity to reform the police use of biometrics and surveillance, build public trust and provide assurance of ethical practice and leadership.

“I am working closely with the Home Office to explore the relevant issues, benefits and risks. I will do whatever I can to ensure this important area of public accountability emerges stronger and clearer for us all.”

Watch our interview earlier this year with Professor Fraser Sampson, below. 

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