Correspondence

October 2020

Updated 2 September 2021

Welcome to the 11th edition of my newsletter.

Tony Porter

Surveillance Camera Commissioner

Introduction

Since my last newsletter, I have been reflecting on the ramifications of the Court of Appeal judgement regarding the South Wales Police’s use of automatic facial recognition technology. I am pleased to report that I intend to re-issue my police guidance in November 2020 that will incorporate the observations of the Court of Appeal regarding where the police use fell outside of the ‘according to law’ requirement - namely on Watchlists and location of use. I will also strengthen the observations on ethical framework.

In this issue, you can read about the main recommendations from my recent survey of local authorities, the CCTV User Group Conference and my chat with Brian Sims, the editor of the Security Matters Podcast.

You can follow links to the most recent blogs, news stories and case studies published on my website. It’s been a busy couple of months for me and the team and I hope you find what’s in this edition useful. Please forward this to anyone you think may be interested and they can subscribe to receive the newsletter themselves by completing a short online form.

In focus – National Surveillance Camera Strategy: Training

In this issue we are taking a look at what’s happening in the training strand of the National Surveillance Camera Strategy.

Setting high standards of training is essential if the public are to have faith in how surveillance camera systems are operated in an open and transparent manner. If standards are to be raised, training needs to be harnessed across the relevant surveillance camera sectors and be visible and available.

The training strand seeks to drive up standards across roles in the industry including designers, installers and managers of surveillance camera systems by providing information and access to relevant training courses.

The training strand of the Strategy is led by Gordon Tyerman, Managing Director, CCTV Training & Logistics. Training is a key part of the strategy as follows:

Objective 5 – Make information freely available about training requirements and provision for all those who operate, or support the operation of, surveillance camera systems and those who use the data for crime prevention/detection or public safety purposes.

Gordon said:

With the development of technology and surveillance camera systems moving at such a fast pace, it is essential we train our designers, installers, managers and operators to the highest level. CCTV images have become the “go to” evidence for police forces across the UK and civil litigation make use of CCTV images in cases every day.

My aim is to provide a comprehensive reference document which will give current and future users of CCTV surveillance a place to find how they can develop the skills and knowledge they will need to deliver a gold standard CCTV for the UK. I am also involved with the National Police Chiefs Council (NPCC) on the development and introduction of an updated national standard for the different roles within the police service when dealing with CCTV surveillance evidence.

Local Authority survey report and recommendations

My office recently conducted a survey of Local Authorities in England and Wales to assess compliance with the Protection of Freedoms Act 2012 (PoFA) and the Surveillance Camera Code of Practice (SC Code). The survey report included 3 recommendations for local authorities to consider and implement:

• enhanced compliance with PoFA and the principles of the SC Code.
• ensure that appropriate governance arrangements are in place (including appointment of a Single Point of Contact (SPOC), completion of the SCC’s Self-Assessment Tool (SAT) and Data Protection Impact Assessments (DPIA).
• robust oversight and accountability of partnership arrangements with third-party operators of surveillance camera systems

For more details on how authorities responded to the survey, you can read my recent blog on the local authority survey report on my website.

The Security Matters Podcast

In this episode of the Security Matters Podcast, I discussed the biggest surveillance challenges facing the security industry, the impact of the Ed Bridges judicial review case on policing and automated facial recognition technology with the magazine’s Editor Brian Sims.

CCTV User Group / NASCAM conference ‘Vision 2021’ event - 19-21 April 2021

The CCTV User Group’s mission is to represent, support, advise and serve the UK CCTV industry. The group represents its Members at highest-level strategic forums where it plays an active part in making sure that new policies, standards or strategies help to improve the delivery, management and use of CCTV for its Members and the public.

I have been invited to deliver the keynote presentation at the next CCTV User Group Conference, which will showcase the very best of all that UK security sector has to offer including:

Workshops - For beginners and pro’s alike, you will always find the answers you’re looking for at these events. From GDPR, system software, and hardware advice to policy and procedures to maintenance contracts; the CCTV User Group conference has it all.

• presentations - Bringing you the hottest topics from the best presenters available. All the presenters are there because they have something you should know.
• networking - The original CCTV industry networking event, bringing people together that share your challenges alongside the best minds in the industry.
• exhibitions - The exhibitors align directly with your services and may already be a supplier to you. They bring the finest products and innovations available from the best providers in the UK today.

To discover more information about this event, who the other speakers are, and how to book a place, visit the CCTV User Group website. Members receive discounted attendance at the conference where you can learn from industry professionals about the future shape and impact of emerging technologies & innovations.

Raising standards – Third Party certification scheme

Under the provisions of the Protection of Freedoms Act 2012, police forces and local authorities must pay due regard to the Surveillance Camera Code of Practice (SC Code) – for other organisations adoption of the 12 principles in the Code is voluntary.

My third-party certification scheme enables organisations to visibly demonstrate they comply with the Code by displaying my certification mark. Congratulations to the following organisations who’ve been issued my mark in the last quarter:

• National Car Parks Ltd
• Police Service of Northern Ireland
• TCMC Crowded Space Ltd
• London Borough of Hackney
• Cheshire East Council

A list of certified organisations is also displayed on my website and updated monthly.

Details about the scheme are available on my website or you can contact my team at [email protected] for more information.

Raising standards – Secure by default self-certification scheme

Secure by default: self-certification of video surveillance systems (VSSs).

Self-certification allows manufacturers of surveillance camera devices and components to clearly demonstrate that their products meet minimum requirements to ensure that they are secure by default and secure by design.

It will mean that the UK’s resilience against cyber security attacks via VSSs is higher. The new requirements are an important step forward for manufacturers, installers and users alike in providing the best possible assurance for stakeholders that products aren’t vulnerable to cyber-attacks.

A list of organisations is also displayed on my website and updated monthly.

In the news – recent events, news and publications

News stories, speeches and articles:

• read my response to the Court of Appeal judgment (R) Bridges v South Wales Police on Automated Facial Recognition.

Surveillance Camera Commissioner’s blogs:

• what’s next for automated facial recognition? In this blog I reflect on the Court of Appeal judgment regarding the police use of automated facial recognition and what steps now need to be taken in relation to it.

If you did not receive this newsletter directly, you can register to receive future editions by completing a short online form.

Tony Porter

Surveillance Camera Commissioner

[email protected]