FOI release

BSCC-FOI-0323-OC: police survey 2022

Updated 10 January 2024

From:

Professor Fraser Sampson
Biometrics and Surveillance Camera Commissioner
2 Marsham Street
London SW1P 4DF

Published 16 March 2023

To: [redacted]

Our Ref: BSCC-FOI-0323-OC

Letter by email

Dear [redacted]

I write in response to your email received by our office on 21 February 2023 in which you ask for more detailed information on West Yorkshire Police’s (WYP) response to my 2022 Police Survey. Your request has been handled as a request for information under the Freedom of Information Act 2000.

In answer to question 1 where you ask, does your system have any cameras or equipment manufactured or supplied by surveillance companies outside the UK about which there have been any security or ethical concerns?

WYP confirmed no for CCTV, live facial recognition (LFR) and BWV.

For automatic number-plate recognition (ANPR), all equipment has been procured in line with force procurement policies and to existing government procurement advice, of which ethical considerations are an integral factor.

For drones, WYP operate 20x UAVs manufactured by DJI, a Chinese company. The capabilities of these UAVs include optical and thermal imaging, and the controllers are connected to the internet via wi-fi hotspots for software updates etc. These UAVs are flown in both operational and training environments and can deliver a livestream direct from the controllers to an RTMP stream address held by GoodSAM, a compliant data storage system, where footage is held in accordance with MOPI.

In answer to question 2 where you ask if the WYP operates external public space CCTV, please describe the system and its capabilities, including the number of cameras and whether the system uses visual only or audio-visual capability.

Yes. WYP operate a milestone video management system with recording (audio and visual) and retention capabilities.

In answer to question 3 where you ask does the WPS’s system have any cameras or equipment manufactured or supplied by surveillance companies outside the UK about which there have been any security or ethical concerns?

Please see answer to question 1.

In answer to question 4 where you asked if WPS uses ANPR provide a description of the system and its capabilities including camera numbers if known.

WYP operate a number of fixed site ANPR cameras across the force covering 700 lanes of traffic gathering data of vehicles passing the locations. The sites are located in positions where intelligence and crime patterns justify their presence. Each fixed camera is subject to a privacy impact assessment that is annually reviewed to ensure continued justification and proportionality. National ANPR standards (NASP) compliance checks are also completed annually and recorded. Temporary sites are only used where there is a fully signed up directed surveillance authority to cover their use.

In answer to question 5 where you ask, has data protection impact assessment or human rights impact assessment been completed for this system?

Yes

In answer to question 6 where you ask, does your system have any cameras or equipment manufactured or supplied by surveillance companies outside the UK about which there have been any security or ethical concerns?

Please see answer to question 1.

In answer to question 7 where you ask if WPS uses body worn video, please describe the system and its capabilities.

WYP routinely use it, with both audio and visual capability.

In answer to question 8 where you ask if WPS uses UAV born cameras please specify capability, visual only/audio visual, thermal imaging, or night vision.

Yes, WYP operate 27 UAV based camera systems to support public safety at events and to provide a spontaneous aerial imagery capability to ongoing police incidents. This includes an indoor search UAV capability operated by Firearms teams.

The imagery comprises conventional optical cameras (including some with a low light capability), radiometric thermal cameras and in the case of the indoor search UAV, a microphone. The UAVs have a livestream / downlink capability via a Microsoft Teams based system and also via the GoodSAM application.

In answer to the second part of question 8 where you ask, does your system have any cameras or equipment manufactured or supplied by surveillance companies outside the UK about which there have been any security or ethical concerns?

Please see answer to question 1.

In answer to question 9 where you ask, does WPS operate facial recognition technology?

WYP use retrospective facial recognition technology (FRT).

In answer to the second part of question 9 where you ask if the answer is no, please answer whether WPS is intending to use FRT in the future. If so, please provide details of the type of FRT and plans for future deployment.

WYP are conducting research and scoping into the use of FRT in policing. These are very early stages and no decision has been made at this time.

In answer to the third part of question 9 where you ask if the answer is yes, does your system have any cameras or equipment manufactured or supplied by surveillance companies outside the UK about which there have been any security or ethical concerns?

Please see answer to question 1.

In answer to question 10 where you ask does WPS have partnership or other arrangements with any of the following in the operation of any surveillance camera system for a policing purpose?

Please specify any local authority or other public body, commercial or private sector body, or local residents/neighbourhood groups. Please name any in Leeds.

None of the above.

In answer to the second part of question 10 where you ask, please indicate the nature of the partnership arrangements by reference to any data sharing protocols, data protection impact assessments, partnership agreements, codes of practice or service level agreements.

No answer was provided by WYP to this question.

In answer to question 11 where you ask, how is WPS held to account for its performance in relation to biometrics and surveillance cameras generally? For example, internal audit/assessment/review, deputy mayor or deputy mayor for Policing, Special Working Group, Ethics Advisory Panel.

Capture of biometrics generally falls into two areas – within the criminal justice environment (custody/voluntary attender processes) and via scan on handheld devices to establish identity. Custodial related (live-scan) processes are monitored nationally and quality checked via Fingerprint Bureau and issues picked up by the Force Custody Services department who have governance of that area, to improve performance/ensure policy compliance and reporting to a chief officer portfolio holder.
<br<Use of biometrics on hand-held devices is overseen by the Force Business Readiness lead (chief inspector) and force performance in that area is monitored and reported on at Local Accountability meetings (chaired by the SIRO).

Use of “biometrics” has been subject of independent scrutiny via Independent Advisory Groups and discussed via Ethics Committee plus has had input from the Deputy Mayor following discussions with community representatives. EHRS forms and DPIA’s have been competed for use of “biometrics” on hand-held devices.

In answer to the second part of question 11 where you ask, have you obtained third party certification against the Surveillance Camera Code of Practice, if not please give reason(s).

No. WYP were not aware the scheme existed.

If you are dissatisfied with this response, you may request an independent internal review of our handling of your request by submitting a complaint within 2 months to the address below, quoting reference BSCC-FOI-0323-OC.

If you ask for an internal review, it would be helpful if you could say why you are dissatisfied with the response.

[redacted]

As part of any internal review, our handling of your information request will be reassessed by staff who were not involved in providing you with this response.

If you remain dissatisfied after this internal review, you would have a right of complaint to the Information Commissioner as established by section 50 of the Freedom of Information Act.

Kind regards

Fraser Sampson
Biometrics and Surveillance Camera Commissioner
Email: enquiries@obscc.org.uk