If you sign up to the compliance package of CCTV Logbook we help you meet CCTV best practice by following the 12 Guiding Principles of the UK government’s Surveillance Camera Code of Practice. The updated Code came into effect on 12 January 2022. This follows a consultation last year into changes to the Code to recognise legal changes since it was originally published in 2014.
The 12 Guiding Principles, which must be followed to comply, have not changed and there are no additional requirements. However, the text has been simplified and there have been updated references to subsequent legislation, in particular the Data Protection Act 2018 which incorporated the UK General Data Protection Regulation (UK GDPR), and the Court of Appeal judgment on live facial recognition in Bridges v South Wales Police.
The code is binding on “relevant authorities” which includes law enforcement authorities, such as the police and local authorities. The Code applies to the use of surveillance camera systems that operate in public places in England and Wales, regardless of whether or not there is any live viewing, or recording of images or information or associated data. The Guiding Principles aim to balance the need for camera systems in public places with individual human rights such as the respect for home and private life, freedom of speech and assembly.
It is hoped that other organisations wishing to operate CCTV systems will voluntarily comply with the 12 Guiding Principles and this is why we used it as our template to ensure you can meet the highest compliance standards and legal requirements. If you sign up and meet the compliance requirements within CCTV Logbook you will be able to download a certificate to demonstrate your compliance.
If you want to go further there is also a self-certification scheme for adopters of the Code organised by the office of the Biometrics and Surveillance Camera Commissioner. Any organisation that successfully achieves certification is awarded a certificate of compliance from the Biometrics and Surveillance Camera Commissioner and are able to make use of the Commissioner’s certification mark on their website and other communications to indicate their compliance with the Code.
Surveillance Camera Commissioner writes to public bodies
The Biometrics and Surveillance Camera Commissioner Professor Fraser Sampson wrote to the relevant authorities last month stating that the revision of the Code provided a timely reminder of their responsibilities when operating surveillance camera systems.
He said that given the level of public attention that can be generated by surveillance technology having regard to the Code would minimise intrusiveness, ensure data protection, provide public reassurance, and reduce the potential for deployments to discriminate inappropriately against individuals or groups.
The Biometrics and Surveillance Camera Commissioner also highlighted that those following the Code should appreciate that some ethical and human rights considerations began before the deployment of CCTV and began at the early stages of manufacturing, procurement, and the contract management of the surveillance camera system.
He wrote, “You may be aware I have significant concerns about the approach of some surveillance camera manufacturers, and I have raised these publicly on several occasions. I am therefore very pleased that the Foreign, Commonwealth & Development Office and the Cabinet Office intend to issue new guidance to enable buyers to exercise their discretion more effectively and exclude suppliers linked with modern slavery and human rights violations from bidding for public-funded contracts.”
Commissioner links CCTV procurement to ethics
Professor Sampson is particularly concerned about the use of CCTV cameras produced by Chinese manufacturers that have been used for surveillance purposes by the Chinese government in their persecution of the Uyghur people in the Xinjiang province of China.
In a speech to the National Police Chiefs’ Council National CCTV Conference 2022 Professor Fraser Sampson referred to last December’s judgment of the Uyghur Tribunal, in which Sir Geoffrey Nice QC found that “Hundreds of thousands of Uyghurs – with some estimates well in excess of a million – have been detained and subjected to acts of unconscionable cruelty, depravity and inhumanity. Sometimes up to 50 have been detained in a cell of 22 square metres, observed at every moment by CCTV.”
The Commissioner said this raised ethical questions. For example, he said, “You wouldn’t employ an individual surveillance operator who had designed, built and worked in one of these appalling places so why would you employ a company that designed, built and operated them?”
While Professor Sampson was addressing local authorities and the Police considering ethics within procurement decisions maybe something commercial and other organisations may want to do due to the nature of the allegations against the specific Chinese manufacturers, that are partly state owned. If you are following the best practice approach of the Surveillance Camera Code of Practice taking into account ethical concerns will protect your reputation too. However, CCTV Logbook can be used whatever brand of CCTV you have.
Sign up to CCTV Logbook to support your compliance
If you want CCTV Logbook to support your CCTV best practice then you can sign up for a 30-day free trial of the cloud-based solution and opt to try out the compliance package as well. We can support you by importing your CCTV assets for free if you book an online product tour that will help you get started. Just try for free or book a product tour right now.