01/FOI/26/007809/X - CCTV & surveillance camera network

Request:

I am writing to make a request under the Freedom of Information Act 2000 regarding the extensive CCTV and surveillance camera network deployed across Withernsea. 

Please provide the following information: 

1. What is the total number of council-operated CCTV and/or ANPR cameras currently active in Withernsea? 

2. Please provide a list or map of all camera locations. (If specific locations are withheld under security exemptions, please provide the total number of streets/roads that have cameras installed). 

3. What was the specific evidence or criteria used to justify the current density of the camera network in a residential/suburban area? 

4. Please provide a copy of the Data Protection Impact Assessment (DPIA) conducted prior to the installation of this system. 

5. What was the total capital expenditure for the procurement and installation of these cameras? 

6. What is the projected annual operating expenditure (OPEX) for this system, including maintenance, licensing and data storage? 

7. Is the system actively monitored by human operators, or does it passively record? 

8. Is the system operated and monitored entirely by council staff, or is this outsourced to a private contractor? (If outsourced, please provide the name of the company). 

9. For cameras equipped with Pan-Tilt-Zoom (PTZ) capabilities, what specific technical or policy safeguards (such as automated digital privacy masking) are implemented to prevent operators from viewing the interiors of private residential properties? 

10. What Key Performance Indicators (KPIs) or metrics is the council using to measure the effectiveness of this system in reducing crime or antisocial behaviour? 

11. Please provide any reports, audits, or data compiled to date demonstrating the system's impact on crime rates in the town since installation.

Response:

With regards to any information about council-operated CCTV, Humberside Police do not hold any information. We would advise that you re-direct your request to the Local Authority.

With regards to ANPR cameras it has been determined that information is withheld by virtue of the following exemptions:

Section 24(1) National Security

Section 31(1) Law Enforcement

Sections 24 and 31 are prejudice-based qualified exemptions and, as such, there is a requirement to articulate the harm that would be caused in confirming or not the information is held; as well as the requirement to carry out a public interest test.

HARM (Section 24 & Section 31):

Disclosure of operational information and camera numbers in relation to ANPR equipment would provide useful intelligence to hostile actors that could impede law enforcement, would weaken and reduce the effectiveness of preventing and detecting organised crime and terrorist activities, and negatively impact on public safety. Disclosure, whether alone or combined with other information in the public domain, could enable a mosaic effect whereby hostile actors build a sufficiently detailed picture of ANPR capability, coverage and performance to identify and exploit vulnerabilities, contribute to a national capability picture, which in turn could be exploited by organised crime groups and those looking to threaten national security.

Releasing the specific information requested would provide criminal and terrorist elements the skills to identify whether equipment is operational, and the means to map and plot more favourable routes and, in turn, the ability to continue, and potentially expand, their activities by working around any faulty equipment. Any information relating disclosed would be likely to assist individuals seeking to evade detection by highlighting environmental or technical conditions under which reads are less effective (e.g. lighting, positioning or partial capture scenarios). The release of camera numbers would provide the means to build up a national picture of ANPR capability, and in turn, highlight gaps which could be utilised for criminal activity.

There is a strong likelihood, due to the low level, operational nature of the data requested, that hostile actors would take advantage and utilise the information to vary their behaviour to avoid detection. Providing data may increase the likelihood of successful avoidance. Revealing areas which could be perceived as more vulnerable, due to the reduced operational availability of ANPR, would likely lead to an increased level of crime in those areas. Any increase in criminality would, in turn, increase the level of policing focus required, divert officers away from other duties, and therefore undermine the Police’s overall primary function of law enforcement and maintaining public safety.

Public Interest Test - S24(1) NATIONAL SECURITY

Factors in favour of disclosure:

Disclosing the information would strengthen accountability to the wider Public, show that funding is being spent appropriately, and improve the Public's confidence that law enforcement has the tools for safeguarding national security.

Factors against disclosure:

Whilst there is public interest in transparency and accountability, there is also an understanding that some intelligence is part of a wider picture and needs to be withheld to enable investigations, both locally and nationally, to proceed in order to protect the safety of the UK. Any disclosure of information that allows hostile agents to increase their activities and endanger the safety of members of the public (and infrastructure) would cause a decrease in the Public's confidence and trust. The operational value of ANPR lies not only in its existence but in the uncertainty around its deployment, capability and effectiveness; reducing that uncertainty would be likely to diminish its deterrent effect.

Balance Test:

Whilst there is interest from the Public for information relating to the use of ANPR equipment, the risk of hostile agents being able to extrapolate the data to increase their criminal or terrorist activities, and in turn, threaten national security outweighs disclosure. Therefore, on balance the Public Interest Test lies in favour of withholding the information and engaging the S24(1) Exemption.

Public Interest Test - S31(1)(a)(b) LAW ENFORCEMENT

Factors in favour of disclosure:

Disclosing the information provides the Public with reassurance that equipment is available to their police force to assist them in the prevention and detection of crime and help keep their local community (and the wider UK) safe; as well as transparency and accountability in respect to public spending.

Factors against disclosure:

Releasing information that enables hostile agents to adjust or increase their criminal activities and prevent law enforcement would endanger the Public and cause them to lose confidence in their police force. Disclosure risks facilitating evasion or crime displacement in and across force boundaries. The release of information which has the potential to risk the safety of the Public, either locally or nationally, would not be in the public interest. There is a strong public interest in preserving the integrity and effectiveness of systems used to prevent and detect crime, particularly where those systems form part of a nationally coordinated capability.

Balance Test:

As releasing the information has the potential to increase criminal activity, both on a local and national level, and increase the burden on the Police Force to carry out their law enforcement duties, and put the safety of the public at risk, on balance the Public Interest Test lies in favour of withholding the information and engaging the S31(1)(a)(b) Exemption.

Therefore, pursuant to Section 17(1) of the Act this letter acts as a Refusal Notice in response to your request.