Protection of Freedoms Bill

Memorandum submitted by Jon Fassbender (PF 55)

General Background information on CCTV

In specific relation to the use of CCTV, whilst the intention of the Bill appears to be a better balance between the operational use of video surveillance systems and privacy concerns, in practice this is a fairly complex matter, given that significant areas of CCTV usage will be outside the scope of the Bill in its current form (and any of the other less than effective legislation already in place). 

Likewise, the wider debate in society (or what little there has been thus far) has chosen perhaps understandably to concentrate on the privacy concerns through misuse of surveillance technology, but rarely if ever focuses on the positive civil liberty related aspects of video surveillance systems, if used appropriately and responsibly.

1) Whilst specialist CCTV has been in use in the UK for almost 50 years, larger retailers have been using video surveillance since the late 1960's, and Town Centre CCTV in it's present guise has now been around for over 25 years.

2) Since an earlier academic guesstimate placed the number of CCTV cameras in use in the UK at around the 4.2 million mark, the same unsatisfactory figure has been repeated ad nauseum  by the worlds media ever since; as indeed has the whimsical suggestion that the average UK citizen is captured on CCTV 300 times a day. 

3) The most recent 1.85 million figure proposed by DCC Graeme Gerrard based on research carried out in Cheshire, whilst adopting a far more sensible and detailed approach to determining a more accurate figure, is probably still not entirely representative of the true picture. For example, Cheshire Constabulary's estimation of 29,700 cameras being operated by Local Authorities, is at odds with the figure obtained by the organisation Big Brother Watch, which determined using Freedom of Information requests that there were around 59,753 being operated by 418 Local Authorities (which responded), to their survey carried out during 2009.

4) Nobody really knows how many CCTV cameras are in use throughout the UK, but given that the earlier 4.2m figure was an enthusiastically inspired guesstimate that undoubtedly over estimated the level of deployment at that point in time, equally the current suggestion of 1.85 million does not in my opinion sufficiently reflect all types of cameras currently being used. On the basis that CCTV cameras have been installed (and replaced when obsolete) on a rapidly increasing scale since perhaps the mid 1980's, it may be reasonable to suggest that if 4 million were taken simply as a figure for discussion, a similar suggestion that perhaps 150,000 cameras in total are being operated by Local Authorities, would imply that less than or possibly around 4% of the CCTV cameras in use in the UK, will be subject to control under the proposed Bill. 

5) Whilst there is no suggestion at present of any licensing arrangement for CCTV, it's worth considering that the average homeowner needs to obtain a licence to watch their favourite episode of "Neighbours" on their TV, but they don't require a license to set up a security camera and watch their next door neighbours ... on CCTV.

6) Cameras designed specifically for ANPR use, are generally "passive" units optimised to one specific task ( i.e. capturing vehicle license plates ) and are therefore relatively efficient for that singular purpose (that's not to say that they don't have an achilles heel). Public Space Surveillance (PSS) cameras are generally deployed as "active" remote control Pan, Tilt and Zoom units, that are required to cover a large area, and as such generally operate at a fairly low level of efficiency.

7) CCTV cameras are normally profiled to fulfill one or more of four discreet functions; namely Deterrence, Incident Monitoring, Site Management and Evidential Recording (DISE). Deterrence and Evidential Recording are essentially "passive" functions that do not require the intervention of an Operator, whilst Incident Monitoring and Site Management are invariably "active" functions, that do require a human interface.

8) The term Public Space Surveillance (PSS) is now widely accepted to cover installations such as Town Centre CCTV schemes. However, it' important to consider that privacy and civil liberty concerns are as much about an individual being captured on private security cameras, whether they are covering public or privately owned and managed spaces. Whether video recorded on a high street, in a corner shop or in the back of a taxi, the same concerns could apply, and the same questions about how the video recordings will be stored and managed arise.

9) Public acceptance and support of CCTV does tend to vary according to the type of technology; for example, anecdotal evidence suggests that whilst overall support for PSS cameras is still relatively high, cameras used for traffic enforcement (issuing Penalty Charge Notices for minor infractions), and "Talking" CCTV, are far less positively regarded.

10) Emerging video surveillance technologies, such as Body Worn Video (BWV), Video Analytics (including facial recognition systems) and 'Listening' CCTV, are less widely publicised and therefore not readily understood by a wider audience; nor indeed are their implications in terms of privacy and civil liberties.

11) A huge percentage of PSS cameras are normally left set on producing wide field "contextual" views, which are generally unsuitable for the purposes of Forensic Surveillance. Given that few if any are routinely supported by audio technology, an Operator is essentially deaf to any sounds being made in close proximity to an individual camera (often located many miles away from the Control Room), and so is unable to respond. It's also worth considering that an average PSS Camera Operator may be responsible for monitoring dozens, or even hundreds of cameras, with efficiency generally reducing, as the camera load increases.

12) Whilst specialist police units such as the Metropolitan Police's VIIDO department are constantly improving the way they recover and manage CCTV recordings, fundamental issues with basic recorded quality and data retention continue to cause major issues, with the vast majority of recorded "product" still regarded as unsuitable for court use.

13) Before privacy safeguards can effectively be built in to the design and operation of a CCTV system, it is vitally important that the operational objectives are correctly profiled and understood. Image quality is actually far more important in terms of addressing civil liberties concerns, than most people would actually consider. 

That aside, it's perhaps worth quickly mentioning that at least a couple of research projects are currently being undertaken around the globe, to look at ways of effectively masking the identity of recorded Data Subjects, but with the facility to switch off the facial obscuration if the images are later required for investigative purposes.

14) It is important to separate the often made misnomer that an area is "covered" by CCTV, particularly with Local Authority operated PSS systems, when in fact it is much more accurate and appropriate to suggest that it is 'coverable'; given that a remote control camera can only point in one direction, at one time.

Interesting to mention in passing that I previously wrote " ... the generally held assumption that a strategically placed pan/tilt/zoom camera can be used to offer sweeping coverage of a relatively large area conveniently overlooks the obvious point - that you can really only look in one direction at one time ..... The use of fixed high quality cameras will also tend to be more in keeping with public concerns about the potential infringement of civil liberties" - those comments were published in an article in the Municipal Journal,  5-11th August 1994!

15) Whilst deterrence is still frequently regarded as a prime motivation for deploying CCTV, in practice, there are two common levels of habituation, that mostly negate any potential deterrent capability. Firstly, "temporal" habituation occurs after a CCTV system has been in place for a reasonable period of time, so the initial novelty quickly wears off, and unless positive results are publicised on a regular basis, the presence of the cameras generally fails to maintain the desired effect over any prolongued period.

16) "Generational" habituation is something which the UK is now the proud pioneer in developing. Whereas the specifiers and developers of early 'Town Centre' CCTV schemes considered deterrence to be the primary desired objective, now a quarter of a century down the line, the next generation have grown up with CCTV as a normal part of the landscape, so generally don't have the same emotional responses to the presence of video surveillance cameras. Interesting to note that countries which are now rapidly deploying CCTV ( the US for example) are convinced of the deterrent effects of surveillance cameras, in much the same way as UK practitioners were assured back in the late '80s and early '90s.

17) The concept of enhancing "Deterrence through Detection" (DtD) based on the high profile publicising of successful use of CCTV, has yet to be effectively applied or tested in the UK (or anywhere else as far as I'm aware). 

18) Where Town Centre or PSS cameras are required to provide some tangible level of deterrence to crime or Anti Social Behaviour, it's somewhat ironic that either small discreet pan and tilt cameras, or fully functioning dome cameras are frequently selected, as their design tends to blend in with the town landscape. Less visual prominence almost always equals less deterrent capability. 

19) Counter Terrorism is still one of the most crucial objectives for CCTV, and yet most Public Space systems are not designed or in any way optimised for this vital role.

20) There has been a paucity of research into the effectiveness and optimisation of CCTV usage in the UK, although other countries are beginning to invest in identifying exactly what works well, and what doesn't. Where the UK's pioneering work could have been used as a basis for becoming world leaders in terms of practical expertise, unfortunately that does not appear to be a key objective.

21) Likewise, there has historically been insufficient investment in providing adequate advisory services and technical support for CCTV Operators, particularly Local Authority officers who have frequently been tasked with delivering a technological deployment, that they often don't fully understand.

22) Wider compliance with the Data Protection Act is not always as committed as perhaps it should be. Whilst a significant percentage of CCTV operations are not required to comply, where they are there is often a less than enthusiastic commitment amongst many private system operators.

23) Whilst much of what little CCTV research that actually exists suggests that the technology is less than proven in reducing crime, the fact remains that if applied correctly and with the most appropriate techniques, the potential for crime reduction and significant improvements in trial resolution within the Criminal Justice System, have barely been scratched.

24) The concept of local community based 'passive' "Safety Net" CCTV being deployed for crime reduction purposes is rarely if ever considered, when "active" PSS schemes are generally promoted as the only viable solution; that despite the fact that 'active' systems may cost typically five times the equivalent of a more efficient 'passive' solution.

25) Whilst the debate about potential overlaps between the remit of a 'CCTV' Commissioner and the 'Information' Commissioner have already been touched upon, it's worth mentioning that there is plenty of scope for other regulatory mechanisms to be discussed and considered, for example 'lay' oversight panels for Local Authority CCTV schemes, an Inspectorate to ensure compliance and operating standards are maintained, and the potential benefits of licensing individual CCTV cameras, premises and monitoring facilities.

Protection of Freedoms (PFB) Committee - Comments on Oral Evidence - 

Q34, - Mr Michael Ellis MP addressing DCC Graeme Gerrard - ". there is a proposal in the Bill for increased regulation of surveillance cameras, and I would like to know whether you see a need for that, and what your views are generally. It is also a recognised fact that we will have a code of practice for the development and use of surveillance cameras in the provisions of the Bill. What are your views on that, and on the appointment of a surveillance camera commissioner?"

The use of CCTV in the UK has been long overdue for regulation, in fact I think I first had published my suggestion of the need for some form of Public Surveillance Inspectorate (jokingly called OFCAM) way back in 1995. DCC Gerrard is absolutely spot on in highlighting the concerns that relate to CCTV being used outside of the accepted 'public' domain, this being systems mostly operated now as Public Space Surveillance (PSS) by Local Authorities. Generally speaking, most PSS CCTV systems are already managed in accordance with some form (although not necessarily standardised) Code of Practice, and are to a greater degree managed within the requirements of the Data Protection Act.

The significant concerns are mostly related to non PSS CCTV operation, which possibly accounts for 90 - 95% of CCTV cameras currently in use, and which will apparently not be subject to the provisions of the proposed Bill.

Q38 - Again, DCC Gerrard has highlighted a key issue, which is that as would be expected given the ratio of PSS to privately operated cameras, the everyday problem for investigating officers is the lack of recorded image quality, or as is more often the case, simply the complete lack of (!) Evidential Quality images from privately operated video surveillance systems; again something which is outside of the scope of the proposed Bill.

The issue of precise UK operated camera numbers, whilst not really significant in itself,  has already been mentioned in the previous section of these notes.

Q39 - DCC Gerrard quite correctly raises concerns that regulating the use of ANPR technology will require a more insightful approach, given that the technology and techniques adopted differ significantly from conventional CCTV operation.

Q41 - Mr Vernon Coaker MP's question about a potential conflict between the Information Commissioner and the proposed Surveillance Camera Commissioner is very apposite. In terms of introducing some form of effective regulation of CCTV, although the two Commissioners roles will differ, there will undoubtedly be far more potential for the 'Camera' Commissioner to prove effective in purpose, than simply using the Data Protection Act ( which was never originally intended to regulate the use of CCTV) as the primary regulatory tool. The two areas must be kept separated, as put simply, there is a very real potential for conflict of interest, between basic data management and some more significant operational issues. 

Q45 - The question from Mr Tom Brake MP very succinctly highlights the necessity for any proposed legislation, to cover all CCTV Operators, and not just the relatively tiny percentage of cameras that are managed in the PSS environment.

Q152 - Ms. Isabella Sankey representing Liberty, suggested that " …The Data Protection Act 1998 and the Human Rights Act 1998 apply to most CCTV cameras in terms of the use and processing of images, but the principles in those Acts were not designed to deal with the sophisticated types of CCTV that we now see on the streets." 

The second part of her comment is absolutely correct, both pieces of legislation were never primarily designed to regulate CCTV, however, the first part of her comment is in my opinion fundamentally wrong. The vast majority of CCTV cameras currently in use are not required to comply with the legislation for a number of reasons. 

For example, privately operated "passive" CCTV systems are not required to adhere to the Data Protection Act (DPA), and this has previously been acknowledged by the Office of the Information Commissioner. Likewise a significant number of domestic or residential cameras are exempt (under Section 36), even if they are monitoring public space. Wide field view images (also sometimes referred to as 'contextual' images) which are unable to identify a Data Subject, are likewise not covered by the Act. In practice, it's quite possible that perhaps 20 - 30% of cameras currently in use would in some way be governed by the DPA, and a much smaller percentage subject to any aspects of the Human Rights Act.

Ms. Sankey's subsequent comments about the perception of CCTV being out of step with the reality are again very valid. However it's important to put the research mentioned into context. Simply researching the outcome from what has been done, does not in itself provide any useful insight as to whether an alternative outcome could have been achieved, if the task were approached in an alternative way. 

The current measure of whether CCTV works or CCTV doesn't work, is based solely on the premise that what has been done historically was the correct application of technology. It is my opinion that far more effective use of CCTV could have been achieved, almost certainly at lower cost, if a more appropriate use was made of both technology and techniques.

Q153 - Dr Metcalf very correctly highlights the lack of proper laws to govern CCTV, and highlights the need for " …much better regulation of how CCTV can be established and used"

Mark Stubbs very correctly raises the issue of what should or shouldn't be subject to regulation. The definition of Public Space Surveillance has tended somewhat towards simply resting on the use of video surveillance by Local Authorities in public spaces, and yet privacy and civil liberty concerns are as equally valid in private space which the public have access to. A simple example might be a local authority operated PSS camera that overlooks the street area directly in front of a London Underground station, when compared to one of the many thousands of cameras that are hidden from view, but monitor the general public as they pass through the "Tube" system below street level.

Tim Maloney mentions an interesting point about how "it is very difficult to quantify the effects that CCTV and ANPR might have on the prevention, detection and investigation of crime". As it happens, it need not be that difficult to carry out the research, but of course it would cost money, and thus far very little useful and insightful research has been carried out in the UK.

Q154 - Mr Vernon Coaker MP mentions that the public generally don't complain about CCTV, but then that does raise two points worthy of consideration. The vast majority of the public do not actually know anything significant about CCTV, only what they read in the press and media. Those members of the public who do complain ( and I regularly receive complaints on this specific issue) are often being victimised by Neighbours from Hell that fit their own CCTV cameras up to keep watch on their neighbour victims. This is an increasing problem, and apart from any notional benefit that might in theory be afforded by the Protection from Harassment Act, there is little other legislation that can provide any assistance in this situation.

On the issue of whether too many commissioners spoil the broth, I would suggest that given the highly complex and technical nature of CCTV, the subject of regulation should ideally be placed upon a specific body that has adequate expertise, to address the significant number of issues that are all intrinsically interwoven with the basic arguments surrounding civil liberties. The Information Commissioner is already tasked with matters relating to data and freedom of information, and the objectives of CCTV regulation would almost certainly be better served by a bespoke solution.

Ms Sankey usefully raises the "nothing to hide, nothing to fear" argument, but that unfortunately is a mantra much used by those with least knowledge, on both existing and future CCTV technologies.

Q157 - In response to Mr Steve Baker MP's excellent question, I would have to disagree with Ms. Sankey's suggestion about simply limiting the numbers of CCTV cameras. It actually makes little difference whether there are two hundred thousand CCTV cameras working perfectly or 90% of two million cameras not working well at all, other than the fact that the latter costs a significant sum, and has the additional by-product of creating disenchantment amongst the wider public. Cameras that are failing to perform correctly do no one any good, save for the very slight possibility that they might have some minor value as a visible deterrent (and the CCTV Industry continues to maintain employment).

Setting quotas on cameras will probably not do anything positive, that isn't going to happen anyway given the potential for reductions in numbers under the current 'austerity' climate. Decisions on deploying PSS CCTV cameras should be based on appropriate problem analysis and profiling, and be justified on defined deliverables, and not simply because it seems like a good idea.

Dr Metcalf stated that "The starting point is that CCTV is a form of public surveillance. It should be discouraged, because surveillance is an interference with privacy". In practice, that argument does not for example, relate to the proof of innocence that CCTV can provide during investigations, and indeed the limited number of documented cases where surveillance camera footage has actually resulted in suspects being freed from detention.

In the real world, criminals and terrorists are just as likely to shop in supermarkets and newsagents as anybody else, so the real test of whether CCTV is appropriate in a given location, is whether it's presence can fulfil a number of defined criteria, and whether it's technical quality and management, makes it both 'fit for purpose' and appropriate under the circumstances.

Dr Metcalf's further observation about the public perception of CCTV, is reasonably based on both media reporting, the artistic licence employed in numerous TV dramas, and to some extent, the positive promotion of technology by what is now globally, a very significant industry.

Mark Stobbs comment about 'article 8' unfortunately overlooks the obvious, which is only a relative small percentage of CCTV cameras would currently be influenced by the Human Rights Act.

Tim Maloney's comment "The aim of any legislation should be to strike a balance between the interests of the individual in terms of privacy and the interests of society in terms of the prevention of crime." is both succinct and accurate.

Q158 - Mr John Robertson MP raised the interesting example of the James Bulger CCTV image (1993) which was credited with providing assistance to investigating officers; and yet more recent high profile cases, for example the identification of the bomber David Copeland, was actually impeded due to the very poor quality of PSS CCTV footage, that failed to assist in his speedy apprehension, and thereby prevent the final attack that tragically resulted in the deaths of three people in the Admiral Duncan Pub (1999).

Q164 - Mr Gareth Johnson MP's question actually relates to a couple of very important points. Firstly, as previously mentioned, an individual’s CCTV privacy concerns shouldn't really be relevant to who specifically owns an individual camera; so for example, consider a section of roadway covered by a local authority's remote control camera, alongside an open piazza abutting the pavement, which is monitored by a privately operated property managers remote control camera. 

In this situation, the same person could be viewed by both public and privately owned cameras at the same time, but from different angles - different operators, same potential for privacy concerns?, which incidentally should both be subject to the placement of advisory signage under the Data Protection Act.

The second issue relates to technology; a CCTV camera need not necessarily be fixed on a pole or a wall. Body Worn Video (BWV), including cameras that are capable of transmitting images to a control room whilst the wearer is moving around, are in a technical sense, little different from a camcorder held to the eye - but they are a technological reality. Any member of the public can buy a BWV camera for a few hundred pounds, and record anyone they want at any time, with little legal recourse. Likewise, the increasing availability of miniature covert cameras, whether secreted in sunglasses or jewellery, belts, or a whole myriad of other disguises, are already available for purchase at relatively low cost.

Q169 - Mr Michael Ellis MP suggests that " the establishment of codes of practice might well have a salutary effect on such companies, in terms of their conduct with CCTV cameras?"

Whilst most PSS CCTV schemes are already operated under individual 'Codes of Practice', likewise private operators have been able to adopt / adapt their own COP; if I recall correctly, there was a model COP published by the CCTV User Group back in 2008.

Q283 - The Information Commissioner Mr. Christopher Graham rightly highlights the fact that there are many issues in addition to data protection, that relate to CCTV. Equally his comments on the public’s wider concerns are very valid, but for obvious reasons do not relate to CCTV cameras that are exempt from the Data Protection Act.

Q284 - Mr Graham's pragmatic answer clearly confirms that there is more to the subject of regulating CCTV than simply the sum of two halves. Likewise Mr David Smith has highlighted the lack of complaint / enforcement protocols in the proposals.

Q286 - The areas of responsibility in terms of regulating CCTV and data / privacy are quite separate, and whilst a "CCTV Commissioner" could in theory have total responsibility, perhaps at some future point in time, at present it would perhaps best be left that each commissioner does what they do best, hopefully with some degree of harmonious interaction.

Q289 - Mr David Smith's comment " … if the cameras do not work, we are not concerned, because cameras that do not work cannot intrude on someone’s privacy" is an extremely welcome and significant statement, given that this precise point has been argued by experts for quite some years now. If a CCTV camera / recording is incapable of identifying a Data Subject, then it does not have to comply with the Data Protection Act.

His further comment about lack of CCTV camera performance possibly leading to a false identification (or by implication failing to correctly identify an innocent individual) does indeed have significant privacy implications, but that is fundamentally a technical issue which I don't think is really addressed by the proposed legislation.

Although Mr Smith's comment that CCTV Operators have an interest in "cameras that are efficient", in practice very few are actually set up to perform at an optimal level (ANPR cameras are actually a very good example of technical / operational optimisation). The wider lack of image performance is more to do with lack of knowledge, and less to do with lack of desire. 

Q392 - Councillor Lawrence's suggestion that Local Authority CCTV camera numbers perhaps only equate to around 3% of the global number currently in use throughout the UK, is certainly not an unreasonable suggestion to make. Without splitting hairs, it's almost certainly below 5%  of the total irrespective of how the estimates are arrived at. 

The Councillors observation that any regulatory proposals should equally apply to privately operated cameras are in my opinion absolutely right. Personally I would take the argument a stage further, and suggest that not only private CCTV cameras that cover public spaces, but also private cameras that cover private spaces, that the public have access to … being recorded on a camera in a public library, a petrol station, or a restaurant all amount to much the same implication in terms of an individual’s privacy.

Q394 - Mr Dave Holland stressed that CCTV use by Local Authorities "…is around safety and around traffic zones and so on.". In practice, whilst it is useful to define the operational objectives for a CCTV camera / system, that in itself does not relate to privacy concerns. 

Q400 - Councillor Lawrence makes reference to 're-deployable' CCTV, which as a technique is undoubtedly useful in some situations.But in terms of providing a deterrent effect to criminal activity, it is generally more likely to cause a temporary displacement, in other words it briefly sanitises an area, and when removed the problem (or other problems) return to fill the vacuum.

In terms of privacy, there is little distinction between re-deployable cameras or any other type that are currently in use.

Q403 - relating camera numbers from one location to another, unfortunately creates a bit of a smokescreen. In the US, comparing the very limited uptake of CCTV in San Francisco, against the fulsome embrace of technology in somewhere like Chicago or Lower Manhattan, is equally as unhelpful as comparing the Shetland Islands with Alaska. The Department of Homeland Security grants for video surveillance technology in the US, have been huge compared to recent spends here in the UK, and yet the interesting point is that our cousins across the water haven't really taken the trouble to learn from our experiences here in the UK.

Mr. Michael Ellis MP very usefully observed "There is the suggestion that because a CCTV camera is present it will always catch everything that happens, it will always be facing the right direction, it will always be working, it will always be focused correctly and the images will be of good enough quality".

In terms of Public Space Surveillance, the time honoured approach of placing a remote control camera on a pole and saying that the area is covered by CCTV, is quite frankly nothing more than a nonsense. It would be far more accurate to say that the area is "coverable" given that the camera will only ever be looking in one direction, at one time. 

My earlier calculations on PSS camera efficiency, would suggest that on average, a Town Centre CCTV Camera (generally costing between £15 > £ 25k each) will in practice function at something between 2.5 - 6% efficiency overall. I have long referred to this type of CCTV system design as "lottery surveillance".

The publics widely held "feel good" factor generated by the presence of the cameras, relates to an expectation, rather than a cold hard measure of performance.

Q407 - Mr Tom Brake MP enquired as to whether any more detailed research has been carried out on the cost effectiveness of CCTV. In recent years, very little research has been carried out here on the deployment of CCTV, despite the huge sums spent on the technology. It is a subject now which generates a lot of interest globally, but whereas the UK could easily be at the forefront of applying and operating systems to maximum efficiency, and with due regard to civil liberties, this has regrettably not been the case.

Q440 - Mr Andrew Rennison is absolutely correct in stating that with an almost complete lack of any previous useful research, nobody knows for sure exactly how many CCTV cameras are currently being used in the UK. 

Something approaching an accurate figure would only really become apparent if there was a requirement to licence the use of individual CCTV cameras, something which I personally would be in favour of.

Interesting to note that even back in November 1999, the then Home Office Minister Mr Charles Clarke informed Parliament that "Information on the number of police, public sector and private operators of CCTV systems currently in operation and the number of cameras currently in use is not held centrally"

Q442 - Mr Rennison commented "A lot of the cameras I described as being in quasi-public ownership are in shopping centres and areas to which the public have free and ready access. Is there any real difference between those and local authority-owned cameras?" I would agree entirely with that observation.

Q447 - Again, Mr Rennison's suggestion that both public and private CCTV operation should be viewed equally in terms of regulatory objectives, is entirely sensible and appropriate.

Q451 - Mr Tom Brake MP asks an interesting question relating to CCTV effectiveness; the suggestion based on previous research that cameras in car parks are more effective, is actually relevant to two specific factors. Firstly, historically most car park CCTV deployments have used 'passive' systems, where fixed cameras are optimised to a specific task (in much the same vein as ANPR cameras have one solitary objective). Also, car parks by their very nature are somewhat controlled environments, so it's generally easier to make good use of lower cost technology, in order to achieve results.

Agreed that some up to date useful research is now very long overdue.

The reference to MegaPixel cameras is interesting, as the technology does indeed promise certain benefits, and yet some manufacturers are designing their products to be more attractive to purchasers, whilst negating the potential improvements in technical performance. CCTV cameras work very well when they are optimised to a specific task; if the objective is to broad, then generally speaking they are far less efficient, and somewhat peculiarly, some MegaPixel (high resolution) camera manufacturers are stretching the capabilities of their cameras at the expense of potential quality benefits.

Q453 - The concept of developing CCTV as the next 'forensic discipline', actually holds enormous potential in crime reduction. From where we are now, it's probably fair to say that in terms of  reaching the objective of using video surveillance as a post event form of forensics, we've barely scratched the surface.

Q461 - Steve Jolly referred to previous research that suggests CCTV is failing to reduce crime; purely in a literal sense that is probably correct. What the research fails to show is how the outcomes may have differed if CCTV technology and techniques had been applied correctly in any given situation. 

A simple analogy might be to relate CCTV to vehicles. If someone were setting up a public transport system for the very first time, it would perhaps be more effective and efficient to use double decker buses, rather than two seater sports cars. Firefighters would almost certainly prefer a proper tender rather than a milk float, and most people would find it a lot easier to collect their weekly shopping in a family saloon, instead of using a seven ton truck; they are all vehicles, but they don't all perform the same task. So it is with CCTV; using the right tools in the correct way, would produce significantly different results to those which have been mostly negatively highlighted, in previous research.

Mr Jolly's comment that "If we are going to consult the public, we need to ensure that the public are properly informed, not misinformed" may sound blindingly obvious, but it is an extremely valid point.

Q462 - It isn't in itself sufficient to debate or discuss whether CCTV should be applied at a given location, without a more extensive profiling of the operational objectives, and the most appropriate technology and techniques that would fulfil them.

Q463/4 - I vaguely recall having my review of the document "Looking Out for You" published at the time back in 1994 - unfortunately the situation has scarcely improved since then.

Q469 - Mr Gareth Jones MP very succinctly made the point that if CCTV is used effectively and appropriately, it can cover both sides of the privacy argument admirably. That is perhaps the singular key point about using CCTV in the context of civil liberties; it's capacity to prove innocence before guilt where just, and the capacity to identify guilt and bring justice, before the civil liberties of other individuals are in any way compromised.

Q474 - Much is written about ANPR cameras being fixed on road networks, but little is ever mentioned about mobile ANPR units, and indeed the use of the technology by private organisations / contractors. Vehicles are routinely clamped (often for lapsed Tax discs) by mobile unmarked units equipped with ANPR systems, which is clearly in breach of the Data Protection Act. As with many aspects of the argument, it isn't simply about the technology or it's capabilities, but more often the way it is used / misused.

Final brief comments and conclusions

The previously published "National CCTV Strategy" usefully highlighted a wide range of issues that needed to be addressed. In fact it could be argued that much of what is currently being discussed, should ideally have been addressed many years ago, before most of our current problems had become a matter for concern.

There is now an opportunity for significant steps to be made in the future management and improvement of CCTV usage, although it will require some very careful planning if all concerns are to be addressed within a reasonable timeframe.

Whilst the current proposed legislation sees CCTV considered as part of an overall basket of privacy related concerns, my personal preference would undoubtedly have been to observe the development of a standalone piece of specific legislation, that addresses a wide range of issues affecting the current use (and misuse) of CCTV, whilst also ensuring that privacy and civil liberty concerns are included as an integral part of the design and operation of systems, rather than simply as an add on consideration.

Whilst much attention has previously been focussed on privacy concerns, particularly in relation to the misuse or inappropriate deployment of CCTV, the fact remains that correctly profiled and operated video surveillance can prove hugely beneficial in addressing a wide range of everyday issues. The debate should really be less about how many cameras are actually being used, and more about how well they are fulfilling their intended purpose; provided of course that the purpose has been properly defined from the outset.

April 2011