FOI release

BSCC-FOI-1225-HD: second attachment to email 5, instructions for completion of survey

Updated 12 September 2025

The use of overt surveillance camera systems in public places by police forces in England and Wales and the Home Secretary’s Surveillance Camera Code of Practice.

Instructions for completion

This document is produced in the manner of a ‘self-assessment’ format as you will be providing the information required rather than it being sought by external audit. It seeks to understand the nature of those surveillance camera systems which your police force operates as described at Section 29(6) of the Protection of Freedoms Act 2012 (PoFA) and the extent to which your Chief Officer complies with Section 33(1) of the PoFA and the Surveillance Camera Code of Practice (SC Code).

It is recommended that the information submitted within the relevant sections of this document is provided by those within your force who have sufficiently detailed knowledge of the relevant capability so as to ensure that your submission is accurate.

PLEASE NOTE: This assessment only relates to the operation of overt surveillance camera systems which are deployed in public places in England and Wales. It does not relate to covert surveillance activity which is separately regulated by the Investigatory Powers Commissioner under the provisions of the Regulation of Investigatory Powers Act 2000 (RIPA).

Completion of the form

In some circumstances, a surveillance camera system may be in use by a police force but operated by another “lead police force” as part of a regional collaboration or similar arrangement. Where this applies simply enter the details of the relevant lead force. Only the lead police force which is responsible for its operation need provide the details required by this survey provided that this is made clear in your submission.

‘Verifiably compliant’

Where a force submits that the operation of a relevant system is compliant with Section 33(1) of the PoFA and the SC Code, compliance should be capable of being verifiable by a third party by means of the existence of a suitable record or audit trail. There is a Self-Assessment Tool (SAT) available on the Biometrics and Surveillance Camera Commissioner’s website to assist forces in that regard and guidance that once completed a SAT should be published in the public domain to demonstrate transparency. The completion of a SAT is not however a mandatory requirement of compliance and forces may undertake to demonstrate compliance using other methods. In those circumstances you should simply provide an explanation of these methods when asked in the relevant section.

The survey should be completed and returned to the below email address no later than 26 August 2022. Your Chief Officer and Senior Responsible Officer should have sight of your submission before it is returned to the Commissioner’s office.

For further information, contact the Office of the Biometrics and Surveillance Camera Commissioner at enquiries@obscc.org.uk.

Links which may be useful sources of reference are as follows:

Self-Assessment Tool

The Self-Assessment Tool will help you and your organisation identify if you’re complying with the principles in the Surveillance Camera Code of Practice (SC Code). It should be completed in conjunction with the SC Code and can help to show you how well you comply with each of its 12 guiding principles.

Data Protection Impact Assessment for surveillance cameras

The surveillance camera specific Data Protection Impact Assessment (DPIA) template with associated guidance notes has been developed in partnership with the Information Commissioner’s Office. This reflects updated data protection requirements, for example, the need to register the name of your data protection officer and take their advice when you carry out your DPIA.

Buyers’ Toolkit

The buyers’ toolkit is targeted at small and medium enterprises that are thinking about using surveillance cameras, yet as non-experts want to identify the best solution, before they proceed and invest their time and money in a system.

Passport to Compliance

The passport to compliance is aimed at large public-space surveillance camera systems such as town centre systems operated by local authorities. It should be completed:

(i) for new systems

(ii) for upgrades of systems if it significantly alters or enhances the views obtained

(iii) when additional cameras are added to a system

(iv) when existing systems are extended in terms of view

Third party certification scheme

Third party certification enables organisations to clearly demonstrate that they comply with the SC Code.

Service Level Agreement framework

Guidance for local authority CCTV system owners and police forces to work towards when compiling service level agreements.

REDACTED – information not within scope of request submitted]

Facial Recognition Technology

1. Is your force operating Facial Recognition Technology? Please tick all that apply.

• Live Facial Recognition
• Retrospective Facial Recognition
• Operator Initiated Facial Recognition (mobile phone use)
• Other Facial Recognition Technology (please specify in the text box below)
• None of the above (go to question 91)

2. Please provide a description (no longer than 1 paragraph) of the system/s and its capabilities.

3. What network topology does your organisation use for the video surveillance system?

• Analogue
• IP based but completely stand alone
• IP based, linked to other networks (e.g. corporate network) but has no internet access
• IP based, linked to other networks, and has internet access (even if through a firewall)

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

• Yes
• No (go to question 87)

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

If the answer is yes, please provide in the text box below the date SAT was completed and any subsequent reviews. Please also specify if the SAT has been published on your force’s website.

If the answer is no, please explain how compliance is being demonstrated.

YES/NO

6. Where the system is non-compliant, please explain in the text box below the rationale for this and any future intentions to address non-compliance.

7. 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.

YES/NO

8. Is this system being operated as part of a collaborate approach with other forces? If the answer is yes, please provide details in the text box below of the lead force responsible for operating the surveillance camera system together with the other forces involved.

YES/NO

9. 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).

YES/NO

10. 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.

• Yes
• No
• Not sure

11. Are you aware of the ‘Facing the Camera’ guidance on the Biometrics and Surveillance Commissioner’s website for police use of facial recognition technology to locate persons on a watchlist?

• Yes
• No

12. Do you have any comments relating to facial recognition technology capability which you consider helpful to assist the Biometrics and Surveillance Camera Commissioner?

[REDACTED – information out of scope of request submitted]