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Call for statutory regulation of police number plate cameras amid concerns over accuracy

The UK’s automatic number plate recognition database – one the largest non-military data-gathering systems – records up to 1.2 million false readings of number plates every day. It should be subject to statutory regulation, says an independent watchdog

Britain’s automatic number plate recognition (ANPR) system, described as of one the largest non-military data-gathering systems in the world, faces calls for statutory regulation amid concerns that high-tech cameras are misreading hundreds of thousands of vehicle licence plates each day.

The UK uses a network of 9,000 ANPR cameras, to record and store up to 30 million vehicle records each year, creating a database that is at least as intrusive as the government’s interception of communications data, an independent report presented to Parliament claimed this week.

Tony Porter, surveillance camera commissioner for England and Wales, said last year that – assuming assertions that the system is 97% accurate are true – between 75,000 and 1.2 million number plates were misread by ANPR technology each day, equivalent to more than 400 million incorrect readings each year.

The database, which holds in excess of 20 billion “read records”, can be mined to build up a picture of the location, travel routes, lifestyle and associates of individuals. Mistakes in data collection could lead to people being wrongly arrested or prosecuted, and could also allow criminals and terrorists to move around freely, the surveillance camera commissioner said.

Porter warned there were “issues” with inaccurate location of ANPR cameras, or cameras failing to report their correct location, which might have a “negative impact” on future prosecutions.

“I am yet to be convinced that an assertion that national ANPR meets performance standards…holds water,” he said.

Errors can come from ANPR cameras failing to read number plates correctly, or individuals using number plates that are deliberately designed to confuse surveillance cameras. For example, people can insert a screw between a 1 and a 1 to make it look like an H, the report revealed.

But police have no meaningful data on the accuracy of the automatic number plate recognition system, or to what extent false readings could contribute to miscarriages of justice or wrongful arrests, the report said.

“A key concern is whether the police understand the volume of misreads or missed reads on the database – these are not quantified. To my knowledge there are no meaningful statistics,” said Porter.

Big Brother Watch, a campaigning group, questioned whether the ANPR database was lawful in its current form.

“This extensive surveillance system has no clear legal basis, and it’s arguable that it might never be legally justifiable, proportionate and in accordance with people’s right to privacy,” said Big Brother Watch researcher Griff Ferris.

Automatic facial recognition

The report raises further concerns about the use of facial recognition cameras to identify suspects by matching camera images against 19 million custody images held by police.

Leicestershire Constabulary was criticised by a civil liberties group for lack of transparency when it deployed automatic facial recognition at the Download concert in 2015, in Donnington Park, in what is believed to be the first public use of the technology in the UK.

The Metropolitan Police used similar technology during the Notting Hill Carnival last year to match images of people at the carnival with photographs stored on its Electronic Wanted and Missing System (EWMS). The aim was to identify people who had been previously banned from the carnival, or where there were grounds to believe that people may commit an offense.

Blind spots in surveillance camera regulation

  • It is unclear which regulator is responsible for overseeing automatic facial recognition technology.
  • Police have no meaningful data on the accuracy of automatic number plate recognition (ANPR) or the contribution surveillance cameras make to tackling crime.
  • In is “unacceptable” that police in England and Wales do not have data to show how ANPR, body-worn video cameras and CCTV assist in tackling crime.
  • There are “issues” with inaccurate location of ANPR cameras, or cameras failing to report their correct location, which might have a “negative impact” on future prosecutions.
  • The National ANPR Data Centre (NADC) accepts data from all police force number plate recognition systems, without carrying out any checks on the effectiveness of the ANPR systems used by the forces supplying the data.
  • The NHS and other organisations refuse to adopt the surveillance camera code of practice, considered best practice, unless it is made mandatory.
  • The number of organisations operating surveillance camera systems in the public domain go well beyond those that fall under the remit of the surveillance camera commissioner.
  • There are more than 20,000 active number plate suppliers in the UK, operating in an unregulated environment that seems “tailor-made to defeat the system”.
  • Commercial surveillance equipment fails too easily, and becomes obsolete quickly, making it more vulnerable to cyber attack.

Source: Surveillance Camera Commissioner Annual Report 2016/17

Following a Home Office review in 2017, the home secretary recommended that people who were not convicted of an offence should be allowed to apply for their custody image to be deleted, unless there was any reason to retain it for policing purposes.

“The review appears to leave the oversight and management of the deletion process solely to the police,” said Porter, who argued that there should be greater independent scrutiny and transparency of police custody databases.

Surveillance camera data at risk from cyber attacks

The report warned that cyber attacks posed a growing threat to surveillance cameras. An attack against number plate recognition cameras, for example, could change or add data, making it impossible to use as evidence.

A cyber attack in Washington DC, just days before the inauguration of President Trump, for example, left over half of the surveillance cameras covering the city’s public spaces unable to record footage for three days, until experts were able to remove ransomware from the recording devices.

“The risk potential for intrusion on citizens has significantly increased both by lawful operators of surveillance camera systems and those individuals or state actors who seek to ‘hack’ into systems,” said Porter.

No data on the impact of surveillance cameras on crime

The report revealed that police forces do not collect data to show the contribution that surveillance cameras, including ANPR, make to tackling crime, making the business case for surveillance cameras impossible to assess – an omission Porter argued was “unacceptable”.

“The risk potential for intrusion on citizens has significantly increased both by lawful operators of surveillance camera systems and those individuals or state actors who seek to ‘hack’ into systems”

Tony Porter, surveillance camera commissioner

“I have heard it argued that CCTV provides more evidence for prosecutions than either DNA evidence or fingerprint evidence combined, yet no coordinated approach exists to corroborate this, nor are there any consistent measures or meaningful empirical evidence to support this assertion,” he said.

Regulation ‘woefully inadequate’

The number of organisations that are regulated under the surveillance camera code of practice 2013 (SC code), which aims to ensure camera surveillance is necessary and proportionate, “remains woefully inadequate”, Porter argued.

“This means my ability to regulate an improvement in the operation of surveillance camera systems in the public space is hampered,” he said.

Omissions include the transport sector, education and the NHS. Organisations such as Transport for London, the Highways Agency, rail franchises, airports, seaports, CCTV systems in crowded places, and cameras that cover the critical national infrastructure, should be included as an “absolute minimum”, said Porter.

“It is a nonsense that the smallest of parish councils in England and Wales must have regard to the SC Code…yet the operators of such huge and intrusive systems that invade everyday life of citizens do not,” he said.

Although 93% of local authorities have completed self-assessment tests to show they are taking the SC Code into account, Porter said he had seen no evidence that the code was being applied to surveillance cameras, sports centres, refuse lorries and other local services.

There are concerns over whether local authorities are clearly complying with both surveillance camera and data protection regulations. “This is not acceptable,” said Porter. At least one local authority is using body-worn cameras in a public library.

Some organisations – the NHS, for example – are taking a short-sighted and naive view by arguing, “If it is not a legal requirement, we are not doing it,” said Porter.

Home Office officials have made it clear that they are “not minded” to introduce legislative changes, but Porter said he would continue to press for changes.

The case for more organisations to be given a legal duty to comply with the surveillance camera code of practice is “overwhelming”, he said, adding that he would continue to “lobby government for a more common-sense position”.

Surveillance cameras intrude into everyday life

Advances in technology have led to a huge commercial interest in retail and other industries in connecting video footage with facial and number plate recognition, mobile phone masts and other electronic databases, to profile the age and gender of customers, and offer them targeted advertising.

“The advent of integrated surveillance technologies – cameras, sensors, analytics, biometrics, smart systems – means the ability for the state, and indeed the commercial sector, to physically and intrusively track the citizen in public spaces is well and truly upon us,” said the report.

Camera obscura: estimating the scale of camera surveillance in the UK

  • Research from 2013 estimates the number of surveillance cameras in the UK at up to six million. Today’s figure is likely to be much higher.
  • The UK annual spend of around £2.2bn a year on surveillance camera technology gives some idea of the scale of camera surveillance.
  • Transport for London has approximately 20,000 surveillance cameras, including automatic number plate recognition (ANPR) and CCTV. It shares data from thousands of strategically placed ANPR cameras with the Metropolitan Police.
  • Anecdotal evidence suggests that at least 600 local town, parish and district councils use video surveillance equipment in public places in partnership with police and business.
  • The Metropolitan Police and Greater Manchester Police, taken together, deploy more than 25,000 body-worn cameras.
  • Most of the 418 local authorities in the UK host town centre CCTV control rooms, plus surveillance systems covering housing, leisure, planning and refuse collection, among other areas. They use body-worn video cameras, ANPR and, increasingly, drones.
  • The 43 police forces across England and Wales deploy surveillance cameras, ranging from CCTV in police stations, body-worn video, drones, cameras on helicopters and vehicles, and ANPR. Some forces are using analytics technology, combined with facial recognition, to predict people’s behaviour.
  • 90% of cameras are operated by businesses, quasi-government organisations, public sector organisations, other public sector organisations, the voluntary sector and private households.

Source: Surveillance Camera Commissioner Annual Report 2016/17

These evolving capabilities present new regulatory challenges and may, in the future, lead to the regulator for video camera surveillance being replaced by a regulator for open source surveillance.

The technology already exists to allow sensors at an airport to detect traces of explosives and pass that information to video surveillance networks that can use facial recognition technology to identify individuals, and match them in real time against watch-lists of suspects.

But there are gaps and overlaps in regulatory oversight, which will need to be addressed if the public are to have confidence in surveillance cameras.

“I am concerned at the incrementally intrusive development of surveillance cameras in the everyday lives of citizens,” said porter.

UK is most watched western democracy

Silkie Carlo, director of Big Brother Watch, said the UK was already the most surveilled country of any western democracy – and the surveillance state appears to be dangerously expanding.

She called for the government to take action to protect the public from indiscriminate surveillance.

“It is an outrage that police forces across the UK are using facial recognition in public spaces – effectively biometric checkpoints – in the absence of any clear legal basis or public consent,” said Carlo.

“In addition, TfL, the NHS and schools are operating thousands of surveillance cameras beyond the oversight of the commissioner, and the state is using cameras on our roads to track and record the car journeys of millions of ordinary, law-abiding citizens,” she said.

National surveillance strategy

A national surveillance camera strategy for England and Wales, published in March 2017, will lead to a clearer path for better compliance, regulation and standards for surveillance camera equipment and personnel, according to a report by the surveillance camera commissioner.

The three-year strategy aims to raise standards for camera manufacturers, installers and organisations that make use of surveillance cameras, including better cyber security, and will emphasise the importance of informed consent for surveillance in public places.

The commissioner is working with universities, parking associations, local authorities and public houses to persuade them to voluntarily take up the surveillance camera code. Work is also underway to develop standards for the use of body-worn video cameras.

Marks and Spencer became the first UK-wide retailer to adopt the SC code voluntarily, Barnsley Hospital the first organisation from the NHS, and Nuneaton Ropewalk the first shopping centre to do so.

Source: Surveillance Camera Commissioner Annual Report 2016/17

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