APPENDIX B
NSG Security Consultants
COMPLIANCE AUDIT OF CCTV
(CLOSED CIRCUIT TELEVISION) CONTROL ROOM
OPERATIONS AT EASTLEIGH BOROUGH COUNCIL
Eastleigh Borough Council
Civic Offices
Leigh Road
Eastleigh
Hampshire
SO50 9YN
May / June 2008
Prepared by Tel: 0161 440 8116
Nick Saunders, Partner & Principal Consultant Fax: 0161 355 2328
NSG Security Consultants Email: info@[Link]
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1.0 Introduction
1.1 NSG Security Consultants have been commissioned by Mr Dennis
Chandler, Town Centre Manager, Eastleigh Borough Council, Eastleigh to
undertake a Compliance Audit of the CCTV (Closed Circuit Television)
operations at Eastleigh Borough Council.
2.0 Scope of the Compliance Audit
2.1 The Compliance Audit has involved:
an assessment of the CCTV Operation’s Code of Practice and Operations
Procedures Manual at the NSG Security Consultants Offices in Cheshire;
and
a visit to the CCTV Control Room in Eastleigh on 22 May 2008 when
consultants observed control room operations, consulted with operators
and representatives of the scheme’s management and reviewed records
held in the control room
3.0 Why Undertake a Compliance Audit?
3.1 The United Kingdom has come along way since the first town centre
CCTV surveillance system went ‘live’ in 1984 in Bournemouth. In fact
today some believe that the United Kingdom leads the world in the use of
CCTV technology to undertake surveillance of the public realm. The
following are some of the ‘statistics’ regularly referred to:
The United Kingdom has a quarter of the world’s CCTV cameras installed
There are 14.2 million CCTV cameras in the United Kingdom
A member of the public is likely to be caught on camera 300 times a day
3.2 When CCTV originally appeared it was unregulated and many saw the technology as a
valuable deterrent to criminal activity, but as it’s use has become widespread so concerns
over civil liberties and invasions of privacy have in some quarters arisen. As a consequence
a mass of legislation starting with revisions to the Data Protection Act in 1998 has been
introduced. Despite the legislation some independent organisations, most notably the
comparatively recently established CameraWatch claim that up to 90% of CCTV systems
may be operated ‘illegally’.
3.3 Whilst the latest Information Commissioner’s report on public attitudes
towards public CCTV surveillance shows that public support remains high,
the report also shows that there are increasing concerns and expectations
on the part of the public, particularly with regards to ensuring that public
space CCTV systems are operated in the best interest of those using the
public realm.
3.4 The purpose of undertaking a compliance audit is to ensure that the
system is being operated in such a way as to meet the original objectives
and rationale behind it’s installation, and that no individual or groups of
individuals are being put at risk or prejudice. A key feature of the original
Information Commissioner’s CCTV Code of Practice was the
recommendation that systems should be audited annually to ensure that
they are being properly used, and that the findings of the audit should be
published to provide public reassurance.
3.5 Furthermore, and contrary to popular belief there is no automatic right to
undertake public space CCTV surveillance, it must be justified and regular
auditing of system operation helps to continue to provide justification.
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3.6 However, it should be noted that a compliance audit is not an assessment
of the effectiveness of a public space CCTV system, it is nevertheless an
important assessment of whether or not the system is being operated in
accordance with current legislation, British Standards and other best
practice requirements.
4.0 Undertaking a Compliance Audit
4.1 A compliance audit needs to take account of all relevant legislation, British
Standards and other considered best practice, including but not
necessarily restricted to the following:
Data Protection Act 1984 and 1998
Human Rights Act 1998
Police and Criminal Evidence Act 1984, subsequent revisions and Codes
of Practice
Freedom of Information Act 2000
Regulation of Investigatory Powers Act 2000
Criminal Procedures and Investigations Act 1996
Fifth Report of the House of Lords Select Committee on Science and
Technology, ‘Digital Images as Evidence’
Home Office Scientific Development Branch (HOSDB) Digital Imaging
Procedures and other HOSDB guidance and best practice (where digital
recording is employed)
Guidance published by the BSI (British Standard 7958:2005 CCTV
Management and Operation. Code of Practice) and Office of the
Information Commissioner, including the new Code of Practice on the use
of CCTV
The joint Home Office and ACPO (Association of Chief Police Officers)
National CCTV Strategy
Security Industry Act 2001 and the Licensing of PSS (Public Space
Surveillance) CCTV operators if the operators are contracted personnel
4.2 In essence there are two separate but linked elements to a compliance
audit of a public space CCTV surveillance operation:
ensuring that the system is operated in accordance with the existing
Operations Manual and Code of Practice; and
ensuring the existing documentation used, complies fully with regards to
legislative, British Standard and other best practice requirements
5.0 A Review of the use of the Eastleigh Borough Council Public Space CCTV
Surveillance System in 2007 – 08
5.1 Statistics regarding incidents observed by the CCTV Operators using the Eastleigh Borough
Council’s Public Space CCTV Surveillance System for the 12 month period April 2007 to
March 2008 were provided to consultants.
5.2 In summary:
A total of 2020 incidents were recorded
770 incidents were not categorised
The Eastleigh Police Attended 1489 of the incidents recorded
597 recorded incidents resulted in the detention of 1 or more persons
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The system was used to search for 47 ‘Missing Persons’ and
successfully located 15 of them
6.0 An assessment of the CCTV Operation in accordance with the Current CCTV
Code of Practice and the Operation Procedures Manual
6.1 The assessment of the CCTV Operation in accordance with the current
CCTV Code of Practice and the Operational Procedures Manual was
undertaken with regards to the following:
Purposes of the Eastleigh Borough Council CCTV Scheme
Signage
Dummy Cameras
Control Centre Management and Operation
Control Centre – Security
Ownership / Copyright Issues
Use of Downloaded Images
Cataloguing of Downloaded Discs
Erasure of Recorded Images
Storage of Transferred Images
Use of Sound
Use of and Access to Recorded Images
Control Centre – Procedure for Dealing with Incidents Seen by
Operators
Police Use of Recorded Images
Provision of Recorded Stills
Eastleigh Borough Council Use of Recorded Images
Evaluation, Monitoring and Audit of Scheme
Photo Library
Service and Maintenance
7.0 Summary of the Consultants Findings
7.1 The compliance audit revealed that Eastleigh Borough Council’s Public
Space CCTV Surveillance Management and Operators are substantially
compliant with the Code of Practice and Operational Procedures Manual
governing the proper and legal use of the Public Space CCTV
Surveillance System.
7.2 Non-compliance are few, minor in nature and easily corrected.
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7.3 There are some minor changes required to the Code of Practice and
Operational Procedures Manual in line with changes in legislation, British
Standards and best practice introduced since the documents were first
published.
The Eastleigh Borough Council’s Public Space CCTV Surveillance Management and
Operators should be congratulated on what is one of the best run Public Space CCTV
Surveillance operations reviewed by consultants in more than 12 year