Well - no surprises there then! But what is the Council? What do we discuss and how does it inform me in my role as Surveillance Camera Commissioner?
We meet quarterly. It really does what it says on the tin -provides advice around issues of the day, policy, areas of contention and also it is the governance mechanism for the National Surveillance Camera Strategy (England and Wales).
I benefit from the attendance of civil liberty groups, senior police and local authority representatives, industry and technological specialists as well as fellow regulators who work hard to ensure our collective efforts are easy to understand for those whom we regulate.
Monday's meeting was fascinating. Following on from the high profile media interest concerning a billboard in Piccadilly that has incorporated automatic facial recognition technology within it the issue concerning regulatory focus was discussed. My role, as stated within the Surveillance Camera Code of Practice very clearly states my role in regulating new technologies when integrated with surveillance camera systems. The Code specifically states that it must regulate the potential for intrusion of such technology ‘now and in the future ‘ It goes on to say ‘ any use of facial recognition or other biometric characteristic recognition system needs to be clearly justified and proportionate in meeting the stated purposed and be suitably validated’’. It is important to note that I have a role providing advice regarding validation of such systems - this advice may provide additional substance to the case of legitimacy offered by a police force to deploy such technology.
This is extremely important when police or law enforcement seek to use such equipment as they are ‘Relevant Authorities ‘ within the Code and must demonstrate due regard for the Code. The Advisory Council provided invaluable support and guidance. I benefited from the helpful engagement of the ICO who also have a very keen regulatory interest in the management and processing of data -which is of course what surveillance product or imagery is. Big Brother Watch’s (BBW) Renate Samson, provided challenges concerning Home Office Custody Images policy and was critical that it came 5 years after a High Court Judge (RMC and FJ v Commissioner Metropolis and Secretary of State for Home office 2012) ordered the policy to be reviewed. Of course custody Images may very well be used as the source data base for use of AFR technology. This challenge generated some excellent proposals for the Home Office to consider in terms of allowing greater confidence in the data base and protection of the citizens rights. Renate also raised the findings of her report into use of Body Worn Camera; PART 2-Police. Worth a read and her comments well received - I shall be raising with National Police Chiefs Council on my National Surveillance Camera Strategy representative ACC Tim Jacques .
I look forward to providing further updates from my Advisory Council in due course, but here is a question from me to you; what do you think my Advisory Council should be discussing?