Research and analysis

Initial analysis of the 2022 police survey returns

Published 14 November 2022

In June this year, the Biometrics and Surveillance Camera Commissioner wrote to the chief officers of all 43 geographical forces in England and Wales, the Ministry of Defence, British Transport Police, and the Civil Nuclear Constabulary, asking for details of their use and governance of all overt surveillance camera systems deployed in public places.

The information in this short report is based on an initial analysis of responses to some key questions within the survey, from those forces which had submitted a return^{[footnote 1]}. Further responses are expected, and a full analysis of returns will be published in early 2023.

Headline findings

• Twelve respondents (33%)^{[footnote 2]} to the police survey confirmed they were using surveillance cameras manufactured outside the UK, eleven (30%) of which were using Hikvision cameras. Only two of those respondents said specifically that they were aware of ethical concerns, with majority simply stating that they had not breached any procurement policies and/or government advice.

• None of the respondents indicated that they were using Hikvision body worn cameras.

• Only one force (MPS) stated it was using Live Facial Recognition (LFR) but six noted they had access to either the Police National Database (PND) or the Child Abuse Images Database (CAID^{[footnote 3]}). Thirteen (36%) said they are intending to use LFR in the future but in the vast majority of cases consideration was at an early stage. Those thirteen in addition to the MPS are: Bedfordshire, Cambridgeshire, Cheshire, Hertfordshire, Derbyshire, Devon and Cornwall, Essex, Kent, Leicestershire, Northamptonshire, West Midlands, West Yorkshire, and BTP. Six (17%) said they had no intention of using LFR, while nine (25%) were unsure.

• There is no universal approach to due diligence across forces when considering a surveillance partnership.

• 28 respondents are using drones (78%), of which 26 (72%) involved equipment from DJI.

The Commissioner has noted that “The potential contribution that modern surveillance technology can make to policing is a game changer – if we are to seize the opportunities that this technology offers, we have to use it in a way that maintains the trust and confidence of our communities. That needs ethical leadership and trusted private sector partnerships. We don’t give police surveillance jobs to people who aren’t willing to explain what’s on their CV, so why would we give contracts to companies that refuse to engage in proper public scrutiny of their trading history?”

CCTV

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? If the answer is yes, please include details in the text box below of which company, the types of devices in use, the capabilities of those devices and how many devices are in use (if known).

12 respondents confirmed their use of cameras manufactured outside the UK. And of those 12, 11 indicated that they were using Hikvision^{[footnote 4]}. One other indicated the use of Axis (around which they stated there were no ethical concerns). One stated that they no longer used Hikvision on new installations, which suggests that Hikvision had been used previously. At least two were aware of ethical concerns regarding Hikvision manufactured cameras but in one case claimed that the Home Office had investigated those concerns and were satisfied that there was no evidence of human rights violations.

Forces using Hikvision noted that they had procured these cameras in line with force procurement policies and Government advice, and some stated that the cameras were stand alone and not part of the network.

Facial Recognition Technology

Is your force operating Facial Recognition Technology?

Only one force stated that it was using LFR (from the list supplied). Six had access to PND and two of those to CAID. One other mentioned access to Athena.

Is this system verifiably compliant with Section 33(1) of the PoFA and the principles of the SC Code?

Three answered in the affirmative.

Where the system is compliant, has your force completed the Biometrics and Surveillance Camera Commissioner’s Self-Assessment Tool?

Of those one stated that compliance is demonstrated by using third party CCTV images from public places only where a crime has been committed [and] in order to detect the suspect of the crime. Others noted that the tool did not seem relevant to the system used. One had completed the Tool.

Has a Data Protection Impact/Human Rights Impact Assessment been completed for this system? If the answer is yes, please provide in the text box below the date a DPIA was completed and any subsequent reviews. Please also specify whether the Biometrics and Surveillance Camera Commissioner’s DPIA has been used, or an alternative template.

For the force using LFR within scope a DPIA has been completed using their own template.

For others who referenced PND there was a mixed response: from a full DPIA being completed to relying on the Home Office having completed them as owners/supporters of the system.

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? If the answer is yes, please include details in the text box below of which company, the types of devices in use, the capabilities of those devices and how many devices are in use (if known).

None confirmed as having concerns.

Is your force intending to use facial recognition technology in the future? If the answer is yes, please provide details in the text box below, including the type of facial recognition and any plans for future deployments, etc.

Of those who answered: 13 yes; 6 no; 9 unsure. Of those answering yes, the majority seemed to be at a very early stage of consideration. One had a planned pilot subject to Chief Officer Group approval, and one will continue to deploy LFR where there is an operational intelligence case to support its use.

Other and partnerships

What due diligence have you undertaken to assure yourselves that the companies with whom you are in surveillance partnership (including third- party operators, manufacturers, suppliers, and installers) are in no way connected to activities that involve any element of modern slavery, forced labour or otherwise unethical conduct and/or pose a risk to national security? Please provide details in the text box below.

There is no universal approach. Forces use a variety of means of assuring themselves that partners (where they are used) are not connected to activities involving, for example, elements of modern slavery: use of ISA protocols, adhering to relevant frameworks, adopting government policies, carrying out independent checks and own due diligence, and using codes of practice.

Do you as an organisation consider the cyber security of your equipment? Please explain in the text box below who is responsible for the cyber security in your force, what mitigations you put in place and any areas where there are no mitigations (e.g. UAVs are considered stand-alone so no cyber mitigations).

Every respondent considered cyber security of their equipment in some form or other. Again there was no universal approach. Similarly, the responsible person or unit varied from force to force: information assurance unit, the Chief Information Security Officer, Force SIRO, ICT department, the individual lead on cyber risk, IT cyber security, information security manager. And at a practical level there was mention of firewalls and other means of combating cyber-attacks.

Do you have any supply chain requirements (or do you consider supply chain requirements) in your decisions on purchasing equipment or maintenance contracts? If the answer is yes, please explain in the text box below if there are any issues (such as ethics, modern slavery etc) which would drive you to pay a higher cost for goods and services, or would prevent you from engaging with a supplier?

Of all respondents who entered an answer to this question only one did not consider supply chain requirements in purchasing decisions. Forces clearly strive, in different fashions, to adhere to government procurement rules, actively avoid using some camera systems where there is a known Human Rights concern, actively consider ethical issues or otherwise build in a host of features to address human rights, modern day slavery, and diversity.

TCP and additional information

Prior to completing this survey, were you aware that a revised version of the Surveillance Camera Code of Practice (SC Code) was issued by the Home Secretary in January 2022?

Of those who responded, 28 were aware and four were not.

1. Responses had not been received from Avon & Somerset, City of London, Gloucestershire, GMP, Gwent, Merseyside, South Wales, South Yorkshire, TVP, Wiltshire, and the NCA. ↩

2. The percentages are of those who responded. ↩

3. i.e. to run searches. ↩

4. Bedfordshire, Cleveland, Hampshire, Lincolnshire, Norfolk, Northumbria, North Wales, Nottinghamshire, Suffolk, British Transport Police and the Met ↩