Letter from Martin Beaumont, CCTV Manager,
Cambridge City Council
1.1 Although I hold the post of CCTV Manager
for Cambridge City Council and lead the CCTV Users Group and Professional
CCTV Managers Association on Training and Development, this evidence
is submitted by me as an individual.
1.2 In this paper I would like to address
the following issues:
a. Unregulated CCTV Cameras.
b. The Security Industry Authority Licensing
Scheme for Public Space Surveillance CCTV systems.
c. The Information Commissioner and DATA
Protection Act 1998.
d. The Human Rights Act 2000.
2.1 Prior to the release of this call for
evidence, Lord Holme of Cheltenham, Chairman of the Constitution
Committee is reported as saying "We now have close to 4.2
million CCTV cameras in the UK".
2.2 Where does this figure of 4.2 million
come from? I do not believe that anyone actually knows how many
CCTV cameras there are in this country and I am not confident
that this figure is correct. However the real issue is that if
we use the figure of 4.2 million then only about 500,000 to 750,000
cameras are subject to any sort of control.
2.3 These are the cameras used to monitor
public spaces and are normally owned by local authorities. Although
some private security organisations do operate some systems. Because
these cameras are local authority owned, they are registered under
the Data Protection Act and subject to the Human Rights Act, Freedom
of Information Act, Regulation of Investigatory Powers Act and
several Local Government and other pieces of legislation.
2.4 But what about the other 3.5 million
CCTV cameras. These cameras are installed in commercial and private
premises (people's homes), transport systems and other sites.
Unless they register under the Data Protection Act they are completely
unregulated and the owners can do what ever they like not only
with the cameras but also the images they produce. I have had
a large number of calls over the last few months from members
of the public concerned that neighbours are invading their privacy
but there is little we can do because there are no laws governing
the private use of cameras. These CCTV systems must be brought
under some form of control.
3. SIA LICENSING
3.1 I was part of the committee, which assisted
the SIA in establishing the Public Space Surveillance (PSS) CCTV
Operators Licence. This was seen as an excellent system because
for the first time minimum national standards of training and
vetting were established before a licence could be issued.
3.2 Sadly the SIA's PSS CCTV Licence only
applied to contractors. This immediately established a two tier
system with those monitoring CCTV cameras for others requiring
licences whilst those who looked after their own "in house"
cameras did not. As a result, "in house" systems did
not require licensing and so did not have to submit to minimum
training or vetting standards. This situation is wrong and anyone
who uses a CCTV camera to observe the public must be licensed.
4. THE INFORMATION
4.1 The Information Commissioner has a massive
responsibility and his office is always running to catch up with
advancing technology. His Codes of Practice is already two years
late. The approach they take should change and instead of trying
to role all the technology into one, they should divide it up
into smaller sections to enable them to keep abreast of the advances
and changes in technology and working practices.
4.2 The weakness of the Data Protection
Act is the reliance on people or organisations to register. If
they do not register then there is little the Information Commissioner
4.3 It is my belief that if the registration
onto the Data Protection Act was dealt with in a similar way to
TV Licensing ie when an organisation or individual purchases a
camera, their details are passed onto the Information Commissioners
Office so that registration under the Act can be processed. This
would ensure we had an accurate figure of the number of cameras
in the UK, what they are being used for and we could start to
bring these 3.5 million CCTV cameras mentioned in paragraph 2.4
(above) under some form of control.
5. THE HUMAN
5.1 My real comment on this Act is that
we are missing a central point of information for Human Rights
in this country. We need a Commissioner similar to the Surveillance
Commissioner and Information Commissioner who can offer advice
and guidance, update organisations on changes and legal cases,
produce guidelines and codes of practices and conduct inspections
6.1 There is plenty of legislation and regulation
currently available to ensure that those organisations registered
under the Data Protection Act or systems run by local authorities
respect the rights of the citizens in this country.
6.2 However, the vast majority of CCTV cameras
are unregulated, are not subject to any controls and drive a horse
and cart through individual's rights to privacy. Whilst at the
same time devalue all the hard work done by legitimate systems
to obey the rules and respect the rights of the individual.
6 June 2007