At Cambridge City Council’s Strategy and Resources Committee on Monday the 12th of October councillors will consider adopting their first “corporate and unified” CCTV policy.
I have been actively encouraging Cambridge City Council to improve the way it runs the city’s CCTV systems since since 2005. I want to see a system which is under democratic control, operated in a manner compliant with policies set by councillors, and is minimally intrusive and used proportionately.
Last year the city council used hidden CCTV cameras to monitor independent punters operating from Jesus Green. The council’s procedures prevented them from using their redeployable CCTV to monitor individuals without a senior officer confirming, as is required by the Regulation of Investigatory Powers Act (RIPA), that the surveillance was proportionate and necessary. Council officers avoided these safeguards by getting their “green spaces” department to install the cameras. I spoke at a council meeting highlighted this inconsistency. The new corporate policy proposed is intended to prevent such a situation arising again. Another “headline” element is the decision to review, on an annual basis, if the presence of each of the city’s 422 cameras is still justified.
An Explosion of Complexity and Bureaucracy
According to the papers for Monday’s committee the city council is considering adopting a policy on CCTV and, in addition to that, a series “Codes of Practice” for each of the “systems” the council runs. There is a lot of overlap between the new policy document and the one code of practice which currently exists (for the city centre CCTV). The proposals appear to me to amount to an explosion of bureaucracy; and far from providing the consistency and openness being sought I think they will add complexity without any significant benefits. In the future if I want to understand the council’s position on its use of re-deployable CCTV I’ll have to consult the council’s CCTV policy, two codes of practice (it is to be covered by its own CoP and the public CCTV CoP), the RCCTV deployment guidelines and also related council policies eg. the RIPA policy.
Currently the council’s one existing code of practice covers different types of CCTV, it covers CCTV in Car-parks, CCTV run for third parties (Magdalene College, The County Council, Ely and Soham) as well as the city centre CCTV. I would suggest adding new sections to that existing document for the buildings the council uses itself and the properties the council rents out would be a far simpler solution than the raft of new documents proposed. I would also suggest that the resultant single document could serve as both the code of practice and the council’s policy (the existing guidance could also be merged into it).
Details of the “RIPA Checking Mechanism” are to be included in the Codes of Practice, so we’re not obtaining consistency in that key area. This, combined with the council’s recent decision to expand the number of RIPA authorising officers is not a step towards consistency. The problem of one arm of the council being able to do something which another arm would not be allowed to do does not appear to have been solved.
Specific Comments on the Proposed CCTV Policy
Section 10 – Signage
The new policy (like the code of practice for the city centre CCTV and the guidelines on RCCTV) says that the area covered by cameras is to be signed. In my view the council currently fails to follow this element of its policy; there’s no point keeping a line in the policy if it is to continue to be ignored. The council currently puts small signs on poles; what it doesn’t do in my view though is effectively sign the areas covered. I think that better signage could result in the cameras, particularly those on open spaces, having a greater deterrence and reassurance effect. I’ve asked people standing in areas covered by cameras and more often than not they don’t realise the cameras are present; especially when they’re the of the black tube on the lamp-post variety.
Section 10.2 says areas where covert cameras are being used are not normally signed. This is a change from current / recent practice where the city council has put signs up at recycling areas where there have been problems with fly-tipping warning that hidden cameras are / may be in use. This practice is contrary to a large number of sections of this new policy so perhaps it will stop or has already stopped? Again I’m raising this as there’s no point having a policy saying something if it is not in line with what is being done in practice.
Access to Images / Footage
Section 9.4 is astonishing. It says that when people contact the council to ask for retention of images (to help with insurance claims) in some instances the images will not be saved and their request refused. The council is to reject requests from individuals and insist insurance companies contact them directly. This appears to me to be the council deciding, as a matter of policy, not to comply with elements of the Freedom of Information and Data Protection Acts. It looks to me as if the council is looking to, as a matter of policy, be awkward and unhelpful to residents and others. It’s out of line with the thrust of section 11 (which is badly titled – as it refers to people seeking images and footage of themselves so not only “requests by third parties”).
Section 2.5 states “Individuals will only be monitored if there is reasonable cause to suspect a criminal offence or serious breach of discipline … .” I think it needs to state: “Surveillance will only be targeted at specific individuals or groups if …” As it is the policy makes no sense, given the council is running a CCTV system covering the city centre ad presumably doesn’t suspect all those present in the city of a criminal offense or serious breach of discipline!
What’s Missing from the Policy?
- The suggestion that all decisions to deploy CCTV in novel non-standard circumstances be referred to and reported to councillors has not been taken up. I would have liked to see a safeguard like that in the policy. The policy doesn’t even mention what the Strategy and Resources committee agreed in September 08 – that they should receive monitoring statistics on RIPA authorised and non-standard CCTV usage.
- Details of how the council proactively or on a “live” basis via the video-link share footage with the police are not mentioned; this is probably as its mentioned in the code of practice – but it highlights the problem of having two documents trying to cover pretty much the same ground. Data sharing after the event is covered extensively in the policy, but what the council does in real time is not covered. Why is one situation covered in one document and the other in another?
- I think that sometimes the council ought tell the police when they’ve got material of interest. This is a difficult area to get the balance right; but I don’t think that in all cases the council should only supply footage / information to the police when the police ask. I realise this perhaps something to take up with the police, but I think the city council could do more. I have found it highly frustrating when the city council have let me know they have images of interest following an incident but that they can’t do anything with them unless the police ask for them.
- The council doesn’t use its CCTV for enforcement of minor traffic and parking offences; but it did, belatedly, put up cameras on Hills Road bridge to monitor (and deter) dangerous driving and dangerous overtaking of cyclists. This policy doesn’t make clear what the council’s policy is on not using CCTV for trivial matters and what the threshold of seriousness is before CCTV can be used. That’s clearly the kind of policy I’d expect to see in a CCTV policy document. This is clearly an area where there is a need for political leadership and where councillors should be making their views known publically.
- The policy makes mention of information sharing with those such as PubClub and Shopwatch
- There is no mention of the other public bodies running CCTV in the city; eg. who runs the unsigned camera on the Gonville place crossing. The City Council could the council ask the County Council, and perhaps the police, to follow the City Council CCTV policy too.
- Where’s the policy on if RIPA authorisation is required or not. There’s been a review; but where has it affected the CCTV policy? It would be worth adding “The council’s RIPA policy” – (which I believe is a document from 2000, but has been amended) to the list of policies that the CCTV policy needs to be read in conjunction with.
- It isn’t clear if this policy supersedes the council’s RCCTV deployment guidelines.
- There’s no openness about where and why RCCTV has been deployed. I think that those living within the line of sight of a RCCTV deployment ought be informed it has been installed; told why it has been placed there, and reassured about the privacy zone settings.
- Maps of CCTV deployments are to be centrally collated – will they be published?
- How can the council’s policy say: “Cameras will not be used to monitor the progress of staff or individuals in the ordinary course of lawful business in the area under surveillance.” The council runs a CCTV system covering the city centre; if I walk through the city centre I am monitored by it.
- What’s the council’s policy for charging others it provides a CCTV service to. ie. Why is Magdalene College paying the council for a CCTV service. (The only non-council body to pay such a fee in 08/08) . Why is Magdalene special? Are no other privately owned, publically accessible areas overlooked? (Does it relate to the commercial property on quayside only and not the college buildings on the other side – which ought be in a privacy zone?) Why is this is a special case ?
- The number of hidden cameras possessed by the council is not clearly given in the table – are they included in the statistics or not?
CCTV on the Bin Lorries
I think it would be worth clarifying that the CCTV cameras on the waste collection vehicles are just for reversing — or whatever it is they’re for. Presumably they’re not taking video footage of my rubbish as they tip it out the bin or otherwise using the cameras to snoop?
Cambridge City Council spends a huge fraction of its discretionary spending budget on CCTV. In 2008/9 it spent £491,430.20, though some of this was recouped through charges to other councils. Since I have been carefully watching the council it has cut the costs of CCTV by around £100,000 per year but still appears to have a “money is no object” approach to the department, spending £1,086.40 on two chairs for the CCTV control room last year.