Public Order Evidence Gatherers CCTV Self Assessment

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Name of organisation

Essex Police

Scope of surveillance camera system

Public Order Evidence Gatherers

Senior Responsible Officer

Supt Philip Stinger

Position within organisation

Head of Specialist Operations

Signature

Supt Philip Stinger

Date of sign off

Principle 1

Use of a surveillance camera system must always be for a specified purpose which is in pursuit of a legitimate aim and necessary to meet an identified pressing need.

1. What is the problem you face and have you defined a purpose in trying to solve it? Have you set objectives in a written statement of need?

Data obtained shall be done so in accordance with Management of Policing Information and Regulatory Investigative Powers Act. All officers carrying out the capturing of data adhere to these regulations whilst operating Essex Police equipment. Training in relation to Principle one is incorporated within the basic training provided to all Essex Police Public Order Evidence Gatherers. They will be cognisant of ECHR article 8 when deployed.

2. What is the lawful basis for your use of surveillance?

ECHR article 8 and lawful objective to the task as well as proportionality.

3. What is your justification for surveillance being necessary and proportionate?

Law enforcement and crime prevention in accordance with MOPI and RIPA. If we are in any doubt then we refer to CAB (Central Authorities Bureau) who will give advice.

4. Is the system being used for any other purpose other than those specified? If so please explain.

5. Have you identified any areas where action is required to conform more fully with the requirements of Principle 1?

Yes

Action Plan

Yes- Our officers have identified via the training provider that the equipment in force is becoming old and obsolete. A report is being compiled for the purchase of new more up to date equipment for a decision.

Principle 2

The use of a surveillance camera system must take into account its effect on individuals and their privacy, with regular reviews to ensure its use remains justified.

1. Has your organisation paid a registration fee to the Information Commissioner’s Office and informed them of the appointment of a Data Protection Officer (DPO) who reports to the highest management level within the organisation?

Yes

2. Are you able to document that any use of automatic facial recognition software or any other biometric characteristic recognition systems is necessary and proportionate in meeting your stated purpose?
purpose?

3. Have you carried out a data protection impact assessment, and were you and your DPO able to sign off that privacy risks had been mitigated adequately?

Yes

Before May 2018 the requirement was to complete a privacy impact assessment; this has been replaced by a data protection impact assessment. There is a surveillance camera specific template on the Surveillance Camera Commissioner’s website:

https://www.gov.uk/government/publications/privacy-impact-assessments-for-surveillance-cameras

4. Do you update your data protection impact assessment regularly and whenever fundamental changes are made to your system?

Yes

5. How have you documented any decision that a data protection impact assessment is not necessary for your surveillance activities together with the supporting rationale?

N/A

6. Have you identified any areas where action is required to conform more fully with the requirements of Principle 2?

Action Plan

Not Applicable

Principle 3

There must be as much transparency in the use of a surveillance camera system as possible, including a published contact point for access to information and complaints.

7. Has there been proportionate consultation and engagement with the public and partners to assess whether there is a legitimate aim and a pressing need for the system?

Yes

8. Does your Privacy Notice signage highlight the use of a surveillance camera system and the purpose for which it captures images?

9. Does your signage state who operates the system and include a point of contact for further information?

10. If your surveillance camera systems use body worn cameras, do you inform those present that images and sound are being recorded whenever such a camera is activated?

Yes

11. What are your procedures for handling any concerns or complaints?

Go through IOPC or Professional Standards Department, who then allocate to the Silver Commander in charge of the Policing operation.

12. Have you identified any areas where action is required to conform more fully with the requirements of Principle 3?

Action Plan

Not Applicable

Principle 4

There must be clear responsibility and accountability for all surveillance camera system activities including images and information collected, held and used.

13. What governance arrangements are in place?

There is a clear level of command within the police, as such any deployments of the camera system shall be authorised by a senior officer, before eventually being carried out by trained officers. All data captured is done so and retained in accordance with Management of Policing Information.

14. Do your governance arrangements include a senior responsible officer?

Yes

15. Have you appointed a single point of contact within your governance arrangements, and what steps have you taken to publicise the role and contact details?

Yes

Guidance on single point of contact.

Chief Supt of specialist operations

16. Are all staff aware of the roles and responsibilities relating to the surveillance camera system, including their own?

Yes

17. How do you ensure the lines of responsibility are always followed?

There is a clear line of command for all deployments, authority is sought from senior officers prior to deployment. The operational commander will then deploy those officers responsible for the use of the camera equipment. The equipment shall only be used if the commander feels this is the correct method of obtaining the relevant data.

18. If the surveillance camera system is jointly owned or jointly operated, is it clear what each partner organisation is responsible for and what the individual obligations are?

19. Have you identified any areas where action is required to conform more fully with the requirements of Principle 4?

Action Plan

Principle 5

Clear rules, policies and procedures must be in place before a surveillance camera system is used, and these must be communicated to all who need to comply with them.

20. Do you have clear policies and procedures in place to support the lawful operation of your surveillance camera system? If so, please specify.

Yes

21. Are the rules, policies and procedures part of an induction process for all staff?

Yes

22. How do you ensure continued competence of system users especially relating to relevant operational, technical, privacy considerations, policies and procedures?

Public Order Evidence Gatherers attend an Initial Training Course and then once signed off as competent have to maintain 2 operational deployments and attend a one day refresher package annually.

23. Have you considered occupational standards relevant to the role of the system users, such as National Occupational Standard for CCTV operations or other similar?

Yes

24. If so, how many of your system users have undertaken any occupational standards to date?

We currently have 12 trained public order evidence gatherers, who meet the occupational standards set by College of Policing.

25. Do you and your system users require Security Industry Authority (SIA) licences?

26. If your system users do not need an SIA licence, how do you ensure they have the necessary skills and knowledge to use or manage the surveillance system?

Public Order Evidence Gatherers attend an Initial Training Course and then once signed off as competent have to maintain 2 operational deployments and attend a one day refresher package annually.

27. If you deploy body worn cameras, what are your written instructions as to when it is appropriate to activate BWV recording and when not?

Not Applicable

28. If you deploy surveillance cameras using drones, have you obtained either Standard Permission or Non-Standard Permission from the Civil Aviation Authority and what is your CAA SUA Operator ID Number?

Yes/No

29. Have you identified any areas where action is required to conform more fully with the requirements of Principle 5?

Action Plan

Not Applicable

Principle 6

No more images and information should be stored than that which is strictly required for the stated purpose of a surveillance camera system, and such images and information should be deleted once their purposes have been discharged.

30. How long is the period for which you routinely retain images and information, and please explain why this period is proportionate to the purpose for which they were captured?

Non evidential data shall be retained for a maximum of 28 days after which it shall be automatically deleted. Data that is required for evidential purposes shall be retained only for so long as it is required, this shall be monitored by the officer in charge and once no longer required this data shall be deleted from the system.

31. What arrangements are in place for the automated deletion of images?

The imagery is given to the OIC to comply with MOPi and selected to be reviewed every 28 days

32. When it is necessary to retain images for longer than your routine retention period, are those images then subject to regular review?

Yes

33. Are there any time constraints in the event of a law enforcement agency not taking advantage of the opportunity to view the retained images?

Yes

34. Do you quarantine all relevant information and images relating to a reported incident until such time as the incident is resolved and/or all the information and images have been passed on to the enforcement agencies?

Yes

35. Have you identified any areas where action is required to conform more fully with the requirements of Principle 6?

Action Plan

Not Applicable

Principle 7

Access to retained images and information should be restricted and there must be clearly defined rules on who can gain access and for what purpose such access is granted; the disclosure of images and information should only take place when it is necessary for such a purpose or for law enforcement purposes.

36. How do you decide who has access to the images and information retained by your surveillance camera system?

Master copies of evidential discs are given to the officer in case for the investigation. they comply with MOPI and are in charge of access for interview purposes etc. The SD card is reformatted for use again.

37. Do you have a written policy on the disclosure of information to any third party?

Yes

38. How do your procedures for disclosure of information guard against cyber security risks?

Not held on a computer system.

39. What are your procedures for Subject Access Requests where a data subject asks for copies of any images in which they appear?

Usually through the Subject Access team at Headquarters

40. Do your procedures include publication of information about how to make a Subject Access Request, and include privacy masking capability in the event that any third party is recognisable in the images which are released to your data subject?

Yes

41. What procedures do you have to document decisions about the sharing of information with a third party and what checks do you have in place to ensure that the disclosure policy is followed?

As per Essex Police Policy on sharing of information.

42. Have you identified any areas where action is required to conform more fully with the requirements of Principle 7?

Action Plan

Not Applicable

Principle 8

Surveillance camera system operators should consider any approved operational, technical and competency standards relevant to a system and its purpose and work to meet and maintain those standards.

(There are lists of relevant standards on the Surveillance Camera Commissioner’s website.)

43. What approved operational, technical and competency standards relevant to a surveillance system and its purpose does your system meet?

The equipment used by public order evidence gatherers is recommended by College of policing guidelines, which Essex Police comply with. Particular secure burners are used to produce a master copy of the footage taken during a deployment.

44. How do you ensure that these standards are met from the moment of commissioning your system and maintained appropriately?

Only the above guidance is followed, along with a DPIA assessment of the policing operation.

45. Have you gained independent third-party certification against the approved standards?

Yes

46. Have you identified any areas where action is required to conform more fully with the requirements of Principle 8?

Action Plan

Not Applicable

Principle 9

Surveillance camera system images and information should be subject to appropriate security measures to safeguard against unauthorised access and use.

47. What security safeguards exist to ensure the integrity of images and information?

48. If the system is connected across an organisational network or intranet, do sufficient controls and safeguards exist?

Yes/No

49. How do your security systems guard against cyber security threats?

No footage is stored on devices that could be subject of such a threat.

50. What documented procedures, instructions and/or guidelines are in place regarding the storage, use and access of surveillance camera system images and information?

Due to the nature of policing, information obtained is used for various reasons, photography and videography obtained for evidential purposes shall be retained for only as long as it is required. All data obtained is retained or deleted in accordance with MOPI.

51. In the event of a drone mounted camera being lost from sight, what capability does the pilot have to reformat the memory storage or protect against cyber attack by remote activation?

Not Applicable

52. In the event of a body worn camera being lost or stolen, what capability exists to ensure data cannot be viewed or exported by unauthorised persons?

Not Applicable

53. In reviewing your responses to Principle 9, have you identified any areas where action is required to conform more fully with the requirements? If so, please list them below.

Action Plan

Not Applicable

Principle 10

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.

54. How do you review your system to ensure it remains necessary and proportionate in meeting its stated purpose?

This is reviewed annually against the MOPI regulations

55. Have you identified any camera locations or integrated surveillance technologies that do not remain justified in meeting the stated purpose(s)?

56. Have you conducted an evaluation in order to compare alternative interventions to surveillance cameras? (If so please provide brief details)

Yes/No

57. How do your system maintenance arrangements ensure that it remains effective in meeting its stated purpose?

MOPI guidelines and guidance that have been set to be reviewed

58. Have you identified any areas where action is required to conform more fully with the requirements of Principle 10?

Action Plan

Not Applicable

Principle 11

When the use of a surveillance camera system is in pursuit of a legitimate aim, and there is a pressing need for its use, it should then be used in the most effective way to support public safety and law enforcement with the aim of processing images and information of evidential value.

59. Are the images and information produced by your system of a suitable quality to meet requirements for use as evidence?

Yes

60. During the production of the operational requirement for your system, what stakeholder engagement was carried out or guidance followed to ensure exported data would meet the quality requirements for evidential purposes?

All evidential data captured by equipment used is burned directly onto CD-ROM and produced as a master copy. Crown Prosecution Service guidance is adhered to regarding the standard of evidence provided.

61. Do you have safeguards in place to ensure the forensic integrity of the images and information, including a complete audit trail?

Yes

62. Is the information in a format that is easily exportable?

Yes

63. Does the storage ensure the integrity and quality of the original recording and of the meta-data?

Yes

64. Have you identified any areas where action is required to conform more fully with the requirements of Principle 11?

Action Plan

Not Applicable

Principle 12

Any information used to support a surveillance camera system which compares against a reference database for matching purposes should be accurate and kept up to date.

65. What use do you make of integrated surveillance technology such as automatic number plate recognition or automatic facial recognition software?

Evidence gatherer footage is used to provide best evidence of the worst offences in a public order deployment.

66. How do you decide when and whether a vehicle or individual should be included in a reference database?

Not applicable to public order evidence gathering.

67. Do you have a policy in place to ensure that the information contained on your database is accurate and up to date?

Yes

68. What policies are in place to determine how long information remains in the reference database?

MOPI

69. Are all staff aware of when surveillance becomes covert surveillance under the Regulation of Investigatory Powers Act (RIPA) 2000?

Yes

70. Have you identified any areas where action is required to conform more fully with the requirements of Principle 12?

Action Plan

Not Applicable

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Public Order Evidence Gatherers CCTV Self Assessment

Name of organisation

Scope of surveillance camera system

Senior Responsible Officer

Position within organisation

Signature

Date of sign off

Principle 1

1. What is the problem you face and have you defined a purpose in trying to solve it? Have you set objectives in a written statement of need?

2. What is the lawful basis for your use of surveillance?

3. What is your justification for surveillance being necessary and proportionate?

4. Is the system being used for any other purpose other than those specified? If so please explain.

5. Have you identified any areas where action is required to conform more fully with the requirements of Principle 1?

Action Plan

Principle 2

1. Has your organisation paid a registration fee to the Information Commissioner’s Office and informed them of the appointment of a Data Protection Officer (DPO) who reports to the highest management level within the organisation?

2. Are you able to document that any use of automatic facial recognition software or any other biometric characteristic recognition systems is necessary and proportionate in meeting your stated purpose?purpose?

3. Have you carried out a data protection impact assessment, and were you and your DPO able to sign off that privacy risks had been mitigated adequately?

4. Do you update your data protection impact assessment regularly and whenever fundamental changes are made to your system?

5. How have you documented any decision that a data protection impact assessment is not necessary for your surveillance activities together with the supporting rationale?

6. Have you identified any areas where action is required to conform more fully with the requirements of Principle 2?

Action Plan

Principle 3

7. Has there been proportionate consultation and engagement with the public and partners to assess whether there is a legitimate aim and a pressing need for the system?

8. Does your Privacy Notice signage highlight the use of a surveillance camera system and the purpose for which it captures images?

9. Does your signage state who operates the system and include a point of contact for further information?

10. If your surveillance camera systems use body worn cameras, do you inform those present that images and sound are being recorded whenever such a camera is activated?

11. What are your procedures for handling any concerns or complaints?

12. Have you identified any areas where action is required to conform more fully with the requirements of Principle 3?

Action Plan

Principle 4

13. What governance arrangements are in place?

14. Do your governance arrangements include a senior responsible officer?

15. Have you appointed a single point of contact within your governance arrangements, and what steps have you taken to publicise the role and contact details?

16. Are all staff aware of the roles and responsibilities relating to the surveillance camera system, including their own?

17. How do you ensure the lines of responsibility are always followed?

18. If the surveillance camera system is jointly owned or jointly operated, is it clear what each partner organisation is responsible for and what the individual obligations are?

19. Have you identified any areas where action is required to conform more fully with the requirements of Principle 4?

Action Plan

Principle 5

20. Do you have clear policies and procedures in place to support the lawful operation of your surveillance camera system? If so, please specify.

21. Are the rules, policies and procedures part of an induction process for all staff?

22. How do you ensure continued competence of system users especially relating to relevant operational, technical, privacy considerations, policies and procedures?

23. Have you considered occupational standards relevant to the role of the system users, such as National Occupational Standard for CCTV operations or other similar?

24. If so, how many of your system users have undertaken any occupational standards to date?

25. Do you and your system users require Security Industry Authority (SIA) licences?

26. If your system users do not need an SIA licence, how do you ensure they have the necessary skills and knowledge to use or manage the surveillance system?

27. If you deploy body worn cameras, what are your written instructions as to when it is appropriate to activate BWV recording and when not?

28. If you deploy surveillance cameras using drones, have you obtained either Standard Permission or Non-Standard Permission from the Civil Aviation Authority and what is your CAA SUA Operator ID Number?

29. Have you identified any areas where action is required to conform more fully with the requirements of Principle 5?

Action Plan

Principle 6

30. How long is the period for which you routinely retain images and information, and please explain why this period is proportionate to the purpose for which they were captured?

31. What arrangements are in place for the automated deletion of images?

32. When it is necessary to retain images for longer than your routine retention period, are those images then subject to regular review?

33. Are there any time constraints in the event of a law enforcement agency not taking advantage of the opportunity to view the retained images?

34. Do you quarantine all relevant information and images relating to a reported incident until such time as the incident is resolved and/or all the information and images have been passed on to the enforcement agencies?

35. Have you identified any areas where action is required to conform more fully with the requirements of Principle 6?

Action Plan

Principle 7

36. How do you decide who has access to the images and information retained by your surveillance camera system?

37. Do you have a written policy on the disclosure of information to any third party?

38. How do your procedures for disclosure of information guard against cyber security risks?

39. What are your procedures for Subject Access Requests where a data subject asks for copies of any images in which they appear?

40. Do your procedures include publication of information about how to make a Subject Access Request, and include privacy masking capability in the event that any third party is recognisable in the images which are released to your data subject?

41. What procedures do you have to document decisions about the sharing of information with a third party and what checks do you have in place to ensure that the disclosure policy is followed?

42. Have you identified any areas where action is required to conform more fully with the requirements of Principle 7?

Action Plan

Principle 8

43. What approved operational, technical and competency standards relevant to a surveillance system and its purpose does your system meet?

44. How do you ensure that these standards are met from the moment of commissioning your system and maintained appropriately?

45. Have you gained independent third-party certification against the approved standards?

46. Have you identified any areas where action is required to conform more fully with the requirements of Principle 8?

Action Plan

Principle 9

47. What security safeguards exist to ensure the integrity of images and information?

48. If the system is connected across an organisational network or intranet, do sufficient controls and safeguards exist?

49. How do your security systems guard against cyber security threats?

50. What documented procedures, instructions and/or guidelines are in place regarding the storage, use and access of surveillance camera system images and information?

2. Are you able to document that any use of automatic facial recognition software or any other biometric characteristic recognition systems is necessary and proportionate in meeting your stated purpose?
purpose?