It’s less reassuring
to realise that these Commissioners have slightly different powers, and
overlapping jurisdictions. If you need any enforcement done, then the ICO’s your
man. If, however, you’re after a current list of approved
which standards may apply to the system functionality, the installation and the
operation and maintenance of a surveillance camera system, then the
Surveillance Camera Commissioner will show you his list. He can also provide guidance
on the bodies that are able to accredit performance against such standards. And
the Chief Surveillance Commissioner is always available to advise if the CCTV
systems get anywhere near the domain of covert surveillance.
Got it?
And each CCTV system is supposed to be reviewed each
year.
Principle 10 of the recently published Surveillance
Camera Code of Practice requires that “There should be effective review and audit mechanisms to
ensure legal requirements, policies and standards are complied with in
practice, and regular reports should be published.”
The Code
goes on to explain that: "Good practice
dictates that a system operator should review the continued use of a surveillance
camera system on a regular basis, at least annually, to ensure it remains
necessary, proportionate and effective in meeting its stated purpose for
deployment." [4.10.1]
The code also explains that: "A system
operator should make a summary of such a review available publicly as part of
the transparency and accountability for the use and consequences of its
operation." [4.10.4]
Aficionados of the odd FOI request will be
delighted to think that there is yet another reason will be able to flood
public authorities with a tusamni of requests, giving public officials lots more
work to do. Just how they will be able
to meet their obligations, in the face of heroic budget cuts, is not a matter
for discussion today.
But.
The British Security Industry Association estimates
that here are between 4 million and 5.9 million cameras in the UK today, and
only 1 in 70 of them are controlled by local government.
So, will there be many annual reviews carried
out on the vast majority of cameras, which are actually controlled by the
private sector?
To be honest, I doubt it. Even though the ICO’s
own CCTV Code also recommends annual reviews (and has done so for a very long
time).
If responsible private sector data
controllers did want to carry out an annual review and needed help in knowing
what it was they were supposed to be reviewing, help is at hand. Not only from
yours truly, but also from the ICO, who has helpfully prepared an annual check
list for smaller data controllers. Thankfully, this check list isn’t one of
those awfully complicated documents that take forever to complete. It’s very
simple, actually.
I would offer a prize to the first reader who
tells me where the check list can be found on the ICO’s website. But I can’t, as
all my spare bottles of scotch prizes have recently been offered to my chums at RBS.
If I were you, I would get reviewing. You
never know when the ICO might come along to check whether anyone has done their
annual CCTV homework.
Source:
Image
credit:
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