NW Systems welcomes new Surveillance Camera Code but worries it creates potential for delay in adoption of ‘intelligent’ CCTV cameras in the UK

One of the most significant pieces of news for the UK surveillance world has been the appointment of the new Surveillance Camera Commissioner Andrew Rennison back in September 2012 and the subsequent publication, on 7 February 2013, of a draft Surveillance Camera Code of Practice Pursuant to Section 29 of the Protection of Freedoms Act 2012. The Act promises ‘further regulation of CCTV’ as surveillance technologies improve and potentially threaten individuals’ rights to privacy. Consultation on the draft Code closed on 21 March.

So the new Code needs to be seen in the context of existing legislation including the Human Rights Act 1998 and Article 8 of the oft-quoted European Charter on Human Rights. A person’s right to ‘respect for their private and family life, home and correspondence’ is jealously guarded by highly vocal civil liberties groups and anti-CCTV campaigners such as Big Brother Watch.

You might expect NW Systems to object to further regulation of a market which we rely on for a great deal of our sales and installation work. In fact we took a long look at the 12 Guiding Principles of surveillance camera systems which form the heart of the new Code and found it hard to argue with any of them. The reverse in fact: we believe that if these principles are honoured by system commissioners, installers and operators alike, this would strengthen the case for surveillance usage in public places long into the future.

The 12 Guiding Principles demand the following of public place surveillance camera and ANPR systems in England and Wales:

• They must have a ‘legitimate aim’ and be responding to a ‘pressing need’.
• They should take into account the privacy of the individual and periodically review whether this is being properly protected.
• They must have a published contact point for access to information held (see Freedom of Information Act 2000) and be able to direct complaints towards this point of contact.
• They must state clear responsibility and accountability for all surveillance camera system activities including image and information collected, held and used.
• A surveillance system’s rules, policies and procedures need to be in place before it is installed. These need to be communicated with all parties that need to comply with them.
• No images and information should be stored longer than is strictly required for their stated purpose. Images should be deleted once they have served their purpose.
• Access to retained images and information should be restricted. Clear rules must be laid out defining who can gain access to surveillance images and for what purpose.
• System operators should define operational, technical and competency standards relevant to a system and work to meet and maintain these standards.
• Operators must avoid unauthorised access to and use of images.
• Operators must review a system’s usage regularly to ensure legal requirements, policies and standards are being complied with.
• ‘Pressing need’ and ‘legitimate aims’ include support of public safety and law enforcement with the aim of gathering images and information which is of evidential value in a court of law in the event of an alleged crime.
• Where operators of surveillance camera systems are using reference databases to check image content (i.e. facial matching or ANPR) they need to ensure the complete accuracy of that database.

On a first reading the new Code seems little changed from the last iteration published back in 2008. But there are two distinct differences in the fine detail.  Firstly, something that Andrew Rennison himself is championing, is the new concept of ‘surveillance by consent’ which follows the principle laid down for policing, i.e. surveillance should only be deployed where people agree that it serves a purpose to enhance public safety, prevent crime or help catch the perpetrators of crime.

Total transparency and accountability become the watch words. Authorities will have to explain why they have put surveillance cameras in a public place; explain how they are managing (and disposing of) the resulting images and metadata and also be prepared to articulate what the perceived crime threat is in this given area.

The Code also implies the potential for specific standards to be drawn up for more advanced surveillance systems such as ANPR, video analytics and facial recognition systems. It is unclear exactly what those standards might be beyond the stipulation laid out in Principle #12 but this is definitely one for some of the high-end camera manufacturers and analytics software providers to watch. There is an increasing trend to put more intelligence into ‘edge’ devices. UK sales of higher end, analytics-heavy network cameras may be stopped in their tracks if tougher standards are imposed here.

So broadly we are in favour of the new Code but also want to ensure it does not hinder the development and use of new, more effective technologies that further enhance the security we all enjoy.  To this end, we would welcome clarification on how exactly the Home Office intends to test the admissibility of some of the more advanced technologies the new commissioner worries about. More on analytics software testing will follow in the next month NWS Blog.

For further reading go to:

Draft Surveillance Camera Code of Practice

The status of public space CCTV cameras

Andrew Rennison interview by Peter Fry

More detail on the history of the CCTV Code of Conduct

Surveillance camera code of practice comes into force (BBC News)

Are you in favour of the new Code?  Do you think it goes far enough to protect the high levels of support for public space CCTV that the industry is enjoying following the summer 2011 multi-city riots?  Have your say before the Code is finalised in July.

Published on April 5th, 2013 by Frank Crouwel