Many of you who follow my blogs are aware that in March this year I launched the National Surveillance Camera Strategy for England and Wales. At the heart of my approach is the desire to drive up standards across the whole spectrum of surveillance camera systems operating in society. Actually that desire captures everybody –from manufactures and system installers, operators, cyber security, training, retail, businesses, engaging public debate and much much more.
I recently completed a programme of national workshops which were delivered as part of my national strategy. These were open to all local authorities in England and Wales and aimed at understanding and harnessing the diverse challenges and approaches to operating surveillance camera systems within our local authorities. One size doesn’t fit all and understandably organisations must sometimes differ by necessity to achieve similar objectives. However – my strategy has a number of ‘red lines’ which our public authorities must consider when operating public space surveillance camera systems. Compliance with the Surveillance Camera Code of Practice, the Data Protection Act and, where appropriate the Regulation of Investigatory Powers Act 2000 (RIPA) and Criminal Procedures Investigatory Powers Act (CPIA) 1996 are amongst the most significant ones.
So – together with my small team – we went on tour! To Cardiff, Nottingham, London, Liverpool and Leeds. All events were really well attended and the issues raised with me were as diverse as the locations visited.
There was universal recognition and support for my recommendation to local authorities that they establish ‘Single Points of Contact’ (SPOC) as a recognised operational ‘expert’ for all surveillance activity conducted by them. Delegates recognised that whilst it is necessary for the public space CCTV control room to comply with the above red lines it is not ok for the remaining systems operated by a local authority not to be compliant. These systems range from video surveillance cameras operating at recreation centres, at help desks, on bin lorries, to body worn cameras used by civil enforcement officers. When considering the use of advancing technology in society, for example the use of drones and facial recognition systems- the issue of legal compliance in the ethical use of surveillance camera systems are, and will increasingly become matters of public trust and confidence for a local authority. A SPOC is an invaluable asset in such issues and can support local authority legal advisers and practitioners alike.
Delegates also discussed potential synergies between the new data protection officer role mandated under GDPR and the incumbent Senior Responsible Officer that supports enquiries under CPIA and RIPA. A level playing field across local authorities will support and streamline processes and not provide extra burdens. It will also drive up standards. Discussions also touched on work being developed under my strategy to deliver a single framework for a Service Level Agreement between local authorities and the police regarding the use of CCTV.
In what were busy and lively sessions in all locations visited, discussions also centred on Certification, Self –Assessment, Body Worn Cameras, compliant operation of systems and cyber security. The feedback from those attending the event was excellent but without the energy and enthusiasm of the surveillance professionals representing local authorities it could not have been so successful. From my perspective I developed a keener understanding of some of the more practical issues affecting local authorities operating surveillance camera systems.
Thanks for taking the time to read my blogs. May I wish you all a Very Merry Christmas and a Happy New year!
Surveillance Camera Commissioner