FOI release

BSCC-FOI-1225-HD: first attachment from email 5, email to Chief Officers of Police England & Wales

Updated 12 September 2025

First attachment from email 5 (second appended separately)

All Chief Officers of Police England & Wales

By email

CC: Senior Responsible Officers

24 June 2022

Dear Chief Officer

The use of overt surveillance camera systems in public places by police forces in England and Wales: an assessment of compliance with section 33(1) of the Protection of Freedoms Act 2012 and the Surveillance Camera Code of Practice

You’ll be aware that I have a statutory function under section 29(2) of the Protection of Freedoms Act 2012 (PoFA) to encourage compliance with the Surveillance Camera Code of Practice (SC Code) issued by the Secretary of State. As a chief officer of a police force in England and Wales you are a ‘relevant authority’ under the provisions of PoFA and as such are bound by responsibilities arising from section 33(1) to have regard to the SC Code when exercising any functions to which the SC Code relates.

The overarching purpose of the SC Code is “to enable operators of surveillance camera systems to make legitimate use of available technology in a way that the public would rightly expect and to a standard that maintains public trust and confidence” (para 3) and “It is a legitimate public expectation of relevant authorities that they are able to demonstrate how they have had regard to this code” (para 8).

Against that backdrop, I am therefore notifying you that I am now conducting a further assessment of compliance following on from the surveys my predecessor conducted with police forces in England and Wales in 2017 and 2019. A survey document has been forwarded to your force together with this letter and should be completed under the guidance of your appointed Senior Responsible Officer.

The purpose of the survey is to gain a better understanding as to the extent to which chief officers are complying with their statutory responsibilities arising from PoFA and the SC Code in connection with their use of overt surveillance camera systems that fall within the definition of section 29(6) of PoFA. This includes CCTV, ANPR, Body Worn Video, Unmanned Aerial Vehicles, helicopter borne cameras and facial recognition technology but also extends to other systems. The survey also seeks to understand the nature of partnership 2 relationships by the police with other operators of surveillance camera systems, the wider democratic accountability of surveillance activities by each respective force, and uptake levels in my third-party certification scheme.

There is also a section within the survey that provides you with an opportunity to highlight any best practice you may wish to share, to provide information about public attitudes towards surveillance and biometrics generally in your force area, and to give a view on what additional guidance or advice you would find helpful from my office.

The completed survey should be returned to my office no later than 26 August 2022. Should you or any member of your force require any further information regarding these matters then please feel free to contact my office by email at enquiries@obscc.gorg.uk.

Thank you for your assistance.

Yours sincerely,

Professor Fraser Sampson

Biometrics and Surveillance Camera Commissioner

Attachment to email 8 publicly available at this link: MCTD-FacialRecognition-Report-WEB-1.pdf