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Speech to the RESPECT security, convenience and privacy event

The speech was about the transparent use of surveillance camera systems and the need to increase public awareness about why and how they are used.


Good morning and many thanks to RESPECT for inviting me to speak at their conference.

I spoke at the joint RESPECT, SURVEILLE and IRRIS event back in October so I see some familiar and friendly faces in the audience today.

As you will all be aware I’m the Surveillance Camera Commissioner for England and Wales. It’s my role to ensure that surveillance cameras in public spaces protect and support communities rather than spy on them. To help me do this there is the Surveillance Camera Code of Practice. I spoke about this in detail last time.

As technology advances so it seems does the number of devices that can be used to capture your image on camera – CCTV, Body Worn Video, ANPR, Drones, dashboard cameras all combined with the use of facial recognition. Over the last five to ten years we’ve seen an interest in surveillance from civil liberty groups, politicians and the media as well as members of the public and academics like you! We’ve seen the fall out from Snowden, the concerns about the data Google capture when we use their search engine and the Smart TVs record everything in its owner’s home.

In an urban area in the UK you are likely to be captured by about 30 surveillance camera systems as you go about your daily business – not cameras, systems! If you want to know that’s probably around 300 cameras! It’s said the UK has the most surveillance in the world – “one nation under CCTV” as a famous street artist once daubed on a wall in London – those of you with a penchant for street art will immediately know that was Banksy. And that resonates with me somewhat, it’s true. CCTV and other types surveillance camera are everywhere and here to stay. There is no getting away from that – it’s a fact – it’s an estimate that there are around six million cameras in the UK alone (excluding body worn video, dash-cams, helmet-cams and drones). How do you remove something so widespread, so ingrained and such big business? I don’t think you can.

Also, surveillance is needed. You might not have expected me to say that but it’s true. There are bad people out there doing bad things. Most major crimes in the UK use some element of CCTV. This is one reason why people in the UK people like CCTV – research carried out by Synectics last year showed 84% of people support CCTV in a public space.

Regulation of CCTV

So, I don’t view surveillance as a bad thing but it must be proportionate, transparent and effective. In England and Wales through the Protections of Freedoms Act, the creation of my role and the Surveillance Camera Code of Practice I believe we have effective and proportionate regulation – it is light touch. Although it’s a slightly confusing landscape given the overlap with the ICO. I don’t think the public fully understand how surveillance cameras are regulated.

I want to provide leadership in the sector, to be seen as the go to person on public space surveillance cameras. To champion the rights of the citizen against the proliferation of CCTV – to enable them to have a voice. Whilst at the same time working with the industry and users of CCTV to raise standards and to help them be more open about their use of cameras.

Public Blindness

Because there is a key issue that I need to reconcile and that is the extent to which the public know they are being monitored and the factors that affect that. We’re still in the maelstrom of challenging financial times – particularly for the public sector. In this financial year alone (2015-16) councils in the UK will have to find £2.6 billion of savings – a mind-boggling figure!

We’re still in an economy where savings must be made in nearly every aspect of the services provided to the public. Public space CCTV in the UK is not a statutory function that Local Authorities must provide. I am now beginning to see evidence that councils are looking at reducing or already have reduced their CCTV provision.

I’ve seen councils in large towns like Blackpool and Derby stop monitoring their systems twenty-four seven. This is not as the result of a review or public consultation but simply to save money. Some of you might be thinking ‘good, less surveillance’ but I would challenge that and say it may be less surveillance put potentially it results in more ineffective systems.

And as austerity measures continue to bite on public space CCTV will we see a deterioration of standards and training. One CCTV manager has told me financial constraints are leading local authorities to take measures that are threatening the levels of CCTV expertise within them. CCTV managers’ roles are being cut and supervisors with little or no knowledge of CCTV are being left to report to senior managers.

What would the 84% of people who say they support CCTV in public space say if the cameras weren’t monitored and where they are the expertise is diminishing? Would they be less supportive and feel less protected? I’m not sure members of the public are aware of these changes.

I also don’t think they’re aware of what technology can or can’t do. On one hand you have TV programmes like 24 or NCIS depicting a surveillance camera system that can pick out the time on someone’s watch from a million miles away. When in reality lots of CCTV systems are fairly old and will give you a grainy image at best if they’re not HD. On the other hand you have the advent of facial recognition technology. When I was at the event in October I spoke about the database of images that the FBI has – around 51 million images. In the UK our database is touching 18 million images of made up of custody photos - they include photos of people never charged, or others cleared of an offence. I think that’s quite scary and something that the Biometrics Commissioner is looking into.

We’ve also seen it reported that senior police officers have said that CCTV cameras should be placed lower down – at face level – so the new facial recognition technology can be used as effectively as possible.

Again, how well sighted is the average man on the street on these developments? Currently CCTV is perched up high looking down away from an individual’s line of sight. But how would they feel if it was at head height – literally in their face. And how would they feel if they knew the camera set up to protect them was now a device that captured their image which was then put into a database and compared to millions images to see if they are a potential threat. Is that protecting them? Is that keeping them safe?

We’re also seeing an increase in cameras being used for more than one purpose. So, the camera that people thought was there for public safety is now being used for traffic management fifty percent of the time. If this dual use was made more transparent amongst communities would they be happy with this? Or would they be worried that the camera that they understood was keeping their community safe was actually only doing that half of the time. And whilst I’m on traffic management it’s worth briefly mentioning ANPR. In the UK ANPR is everywhere – it’s hardwired into our daily lives. The police use it for counter terrorism and serious organised crime – it’s an essential tool in combating both of these.

More recently ANPR is being used to monitor if road tax has been paid on vehicles. The cameras read licence plates and if the vehicle is not registered as having paid road tax or it’s lapsed a fine will be issued – I have no problem with this.

The ANPR system in the UK captures around 27 million images each day – a huge number. This is surveillance on a massive scale. However, whilst there is some transparency on the number of images captured – which is generally number plates – the total number of ANPR cameras remains a mystery. I can understand why the police would not want to reveal the location of cameras as this could influence how organised criminals use the road network. But I see no downside to saying how many cameras there are – it’s keeping the public in the dark.

So, across the surveillance camera landscape there is certainly a level of ‘public blindness’. As I mentioned earlier research suggests 84% of people in the UK support CCTV – I wonder if they are in the ‘I haven’t done anything wrong so I don’t have a problem with CCTV’ school of thinking.

If their eyes were opened to some of the issues I’ve mentioned – facial recognition, cuts to services and the ANPR database – would the support for CCTV fade? My guess is that it would.

Individuals must be given the full picture so they can make an informed decision around their support for CCTV. If these uses are revealed in sensationalist media articles or through people like Snowden rather than through serious consultation with communities it will only damage the image of surveillance and the good it can do as opposed to the bad.

Civil Liberty Groups

So, it’s about transparency.

This is one of the key concerns of civil liberty groups in the UK. Particularly transparency by relevant authority organisations – although they only account for around five percent of surveillance cameras in the UK.

Civil Liberties groups rightly want to hold authority to account to ensure what they do is lawful and not infringing on the rights of the individual. But I am told time and again that there is a lack of openness.

These groups often have to submit freedom of information requests to gain information on the use of public space surveillance cameras. It’s a convoluted process that causes work for them and the organisations that have to deal with the requests.

But it shouldn’t be like this. One group has told me that if the information they wanted such as number of cameras, locations and uses were on organisations websites they wouldn’t have to take this bureaucratic route. In fact one group looked at every Local Authority website in the UK just by searching the name of the Local Authority and CCTV together. They found that less than a quarter had a clearly accessible CCTV code setting out the reasons for their system. That’s not a good place to be in – they should all make this information easily accessible and in the digital age that’s on a website!

That’s not to say that relevant authorities aren’t good at telling the public what they are doing – lots are. My team and I have visited numerous authorities who publish all you could want on their websites – camera locations, uses and even crime stats in some instances. This is what all organisations should be doing so the public can hold them to account – it’s about consistent standards.

CCTV Industry

And surveillance camera standards is an area of great concern for the CCTV industry. Be it installers, camera operators or manufacturers every time I meet them we talk about standards.

Principle 8 in the Surveillance Camera Code of Practice sets out the responsibilities I have around raising standards across the surveillance camera industry. I also have a standards board dedicated to simplifying the standards framework.

The issue the industry has with standards is that there are no minimum standards also complicated by the fact what guidance is out there is fairly complex and in lots of different places. So, if I’m a small shop owner who wants to have CCTV installed I have no obvious place to go to for information.

This can lead to poorly installed surveillance systems as someone with no knowledge of CCTV can set up as an installer. Stakeholders in the industry tell me there are some outfits who simply ‘nail a camera to the wall’ and leave the owner to work out how to use the system.

This leads to poor surveillance – a badly installed system with an owner who can’t operate it.

The industry are also very interested in who should pay due regard to the code of practice. I said earlier only relevant authorities such as the police and local authorities must pay due regard to the code and that only accounts for around five percent of cameras.

But what about all the other places that the public have access – Universities, Football Stadiums and shopping malls but to name a few. All places that a member of the public would probably consider as public space.

When someone walks form a street monitored by Local Authority CCTV in to a shopping mall monitored by a private company do they consider themselves in a public space – I would hazard a guess that they do. So, why must one organisation comply with the code whereas it’s voluntary for the other?

Should anyone operating CCTV that monitors public space have to comply with the code?

Domestic Use

It’s not just companies using surveillance cameras – there is more and more domestic use of CCTV with individuals installing it to protect their properties. They are able to monitor it remotely on a tablet, laptop or Smartphone – it’s the must have tech for the modern security conscious citizen. It’s becoming much cheaper too – leading to greater use – you can pick up a HD camera for around 40 Euros.

By far an away the most concerns I have from members of the public are around domestic use of CCTV – not commercial or government use. They are concerned about the neighbor who’s put CCTV on the outside of his house which is now overlooking their property, their garden or their bedrooms.

They are often scared and confused not knowing what to do or who to turn to, as the police will often view it as a civil matter or neighbourly dispute for the two parties to resolve.

Some people could be well using surveillance cameras on their homes for mischievous endeavours such as watching their neighbour’s comings and goings. But I sincerely hope that this is a minority.

Until recently there has been little guidance around using CCTV at home. Although I’m sure that you are all aware of the recent EU judgment that means any CCTV that looks beyond the perimeters of the owners dwelling is now captured by data protection laws. So, domestic CCTV now falls under some regulation.

The Information Commissioner is responsible for data protection in the UK and has issued guidance and I work very closely with him. But the guidance is a first step and there is more to be done here.

Should manufacturers or retailers of this kit play a role? Is there scope for them to include information at the point of sale around best practice when installing domestic surveillance cameras? I think there probably is and this is something Information Commissioner and I will be looking at in the future. Review Looking to the future one of my key functions is to review the operation of the code and report back to the Home Secretary. It’s about evaluating how the code is it working? Is it working? What works well and what needs to change? And I’m due to report back my findings in the autumn.

But more than that I want to explore the regulatory landscape that CCTV occupies so I can provide some real recommendations to ministers that will make it better, improve it. And by improve it I mean improve it for all – installers and manufacturers, operators and managers as well as the police as end users and members of the public.

I will be taking into account much of what I’ve discussed here today:

  • Should anyone operating CCTV that monitors public space have to comply with the code?
  • Should minimum standards be in place?
  • What should we do about organisations that aren’t transparent about their use of surveillance?

And I’m keen to get views from all groups to feed into this review including members of the public – those that are monitored.

Those that are monitored and overwhelmingly support the use of CCTV to protect them – 84%. But are they blind to what the cameras are used for, could be used for or will be used for in the future. I believe they are and as we move forward I am determined to help organisations be more transparent.

We are in a world of surveillance – that will not change - as I said at the start of this speech. But what we must do is be open, lift the veil and tell people what the surveillance is and what it’s used for.

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