Over the past six years as Commissioner I have benefited greatly from the commitment, contribution and support received from many quarters. This has unquestionably assisted me and benefitted society and the wider surveillance camera stakeholder community in raising the standards of operating surveillance camera systems in public spaces.
What has always been clear is the huge goodwill amongst those working within the industry. What was less apparent was how the different parts of the industry worked alongside each other – the manufacturers, installers, consultants and operators. I have consistently sought to shift the debate over regulation of these matters from them being simply a data protection issue. This is patently not the case and given the complexity of these matters I launched the National Surveillance Camera Strategy in March 2017 comprising of 10 work-strands (now 11). Each strand represents an important strategic theme requiring action. Taken together they illustrate something of the complexity of the subject matter and each is led by a senior expert. So, almost three years since I launched the strategy I thought it only right to take brief look back.
Implementing a strategy
Regular readers of my blog will have heard from each of the strand leads over the past few years on what they are working on. There’s a strand looking at civil engagement so we can help the public understand how cameras both protect and impact on their human rights. This strand has delivered public debates, forums and the National Surveillance Camera Day to ensure that the public voice had a platform to influence (a note to those in authority who still call for a debate on these matters – we’ve had them, they are ongoing what we need is action). I pay tribute to ‘Liberty’ and ‘Big Brother Watch’ in particular for the well-considered challenges they consistently contribute to those debates. Equally, I pay tribute to police, parliamentarians and fellow regulators for engaging so enthusiastically.
Through the police and local authorities strands we are delivering framework service level agreement where a surveillance camera system is to be used in partnership with others, raising standards on how these partnerships work in practice. They are looking at technological solutions as well as linking in with the training strand of the strategy to identify what more is needed in this space. Also, a survey I conducted of the surveillance camera systems being used by police forces in England and Wales around the nature and extent of statutory compliance highlighted some areas of concern. These in turn led to recommendations being made by me and implemented by all Chief Constables. Marvellous commitment. A similar survey of local authorities is taking place too.
Whilst on standards, the standards strand has led and delivered on the development and delivery of a spectrum of independent and industry standard certification schemes ranging from the operator to the manufacturer. They are branded under the Surveillance Camera Commissioner logo and provide greater reassurance to buyers, users and law makers alike. Through this strand we successfully launched ‘Secure by Default’ last June – a global first where manufacturers of surveillance camera products had to hit minimum cyber security requirements as their product emerges ‘out of the box’ in order to self-certify and receive the SCC mark. Whether you are a manufacturer, installer, designer or user of a system, public or private, there is a standard to be met. Alongside all this the installer strand is refreshing the Buyers’ Toolkit and the guidance we have issued installers to ensure it is completely up to date.
The voluntary adopters strand has successfully worked to promote the adoption of the Secretary of State’s Surveillance Camera Code of Practice (SC Code) amongst business, health and education. Many private sector bodies now voluntarily demonstrate their commitment to public and customer confidence by following the high standards set by the code where they are under no legal compulsion to do so and some have achieved my certification mark. Likewise, through the Centre for the Protection of the National Infrastructure some of the most fundamental facilities in the UK now benefit from surveillance camera systems which operate in accordance with the SC Code.
Regarding my regulation strand I enjoy a healthy and productive relationship with IPCO, the Biometrics Commissioner and the Forensic Science Regulator. I have an MoU with the ICO and our joint work in delivering a DPIA for operators of systems represents an effective reduction in bureaucracy for the stakeholders we oversee.
The newest strand of the strategy focuses on human rights, data and technology and seeks to engage in constructive dialogue with a range of important stakeholders including other regulators, civil society groups, legal experts and, crucially, those who use surveillance cameras to promote public safety. This ties in closely with the horizon scanning strand as do all the other strands.
I haven’t covered here the full multitude of work going on inside and outside of the strategy – this would have to be an entire report not a blog! However, it is important that I emphasise that those leading and contributing to the delivery of the national strategy do so voluntarily. Such is their commitment. Similarly, those supporting me on the many groups I chair take on additional burdens to their day job.
A clear framework but more to do
Through the strategy we now have a clear framework that provides a full system approach to how surveillance cameras are manufactured, installed and deployed. The strategy is due for a refresh and as I come to the end of my tenure as Commissioner this approach to surveillance camera use seems more important than ever – it is a credit to all involved that we have progressed it as far as we have over the past 3 years.
With under two weeks of my Commission left to go I remain unable to advise readers as to Government intentions for the successor to my role. There is much to do and a burgeoning portfolio of issues for that person to address. It is my heartfelt belief that maintaining a strategic approach to emerging overt surveillance is necessary for ongoing trust of its use in our society.
Hopefully, by this time next week, I will have a clearer position to report.