oversight

Video Surveillance: Information on Law Enforcement's Use of Closed-Circuit Television to Monitor Selected Federal Property in Washington, D.C.

Published by the Government Accountability Office on 2003-06-27.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

             United States General Accounting Office

GAO          Report to the Chairman, Committee on
             Government Reform, House of
             Representatives


June 2003
             VIDEO
             SURVEILLANCE
             Information on Law
             Enforcement’s Use of
             Closed-Circuit
             Television to Monitor
             Selected Federal
             Property in
             Washington, D.C.




GAO-03-748
                                               June 2003


                                               VIDEO SURVEILLANCE

                                               Information on Law Enforcement’s Use of
Highlights of GAO-03-748, a report to the      Closed-Circuit Television to Monitor
Chairman, Committee on Government
Reform, House of Representatives               Selected Federal Property in Washington,
                                               D.C.


Law enforcement use of closed-                 The Metropolitan Police Department of the District of Columbia’s CCTV
circuit television (CCTV) as a tool            system was implemented, among other things, to facilitate crowd
to fight crime and terrorism has               management during large demonstrations; however, officials indicated that
become more prevalent over time.               the system could also be used to help combat terrorism. The system is used
Civil liberties advocates have                 on an as-needed basis for such things as crowd control and when the
raised privacy concerns about its
use.
                                               national terrorism threat level is set to high alert (code orange). The
                                               Metropolitan Police Department obtained public comments on its
This report describes (1) the                  implementation of CCTV. In contrast, the United States Park Police uses
Metropolitan Police Department’s               CCTV, among other purposes, primarily to combat terrorism and operates its
and the United States Park Police’s            CCTV system on a continuous basis. The United States Park Police has not
implementation of CCTV to                      obtained public input on its implementation of CCTV, but it is considering
monitor public spaces in the                   providing the public an opportunity to provide input.
Washington, D.C., metropolitan
area such as the National Mall and             The Metropolitan Police developed regulations and the United States Park
(2) the management controls they               Police developed draft policies for operating their CCTV systems. Both
established to address privacy                 include management controls that address the protection of privacy and the
concerns. GAO also identified
                                               proper use of CCTV such as the need for supervision to protect against
experiences of selected CCTV
users that provide insights to help            improper use and the establishment of procedures to control access to CCTV
ensure the proper CCTV use.                    images.

                                               The experiences of CCTV users in the United Kingdom (UK) and selected
                                               U.S. cities revealed best practices for the implementation and use of CCTV.
                                               For example, UK and U.S. officials considered providing training and audits
                                               helpful to ensuring proper use of CCTV. Officials in the UK and others
                                               shared their best practices that include (1) operating CCTV systems in an
                                               open environment helps to alleviate privacy concerns; (2) having uniform
                                               standards helps to reassure the public that safeguards are in place when
                                               utilizing CCTV and provides CCTV operators guidance for proper use; and
                                               (3) establishing realistic, clear, and measurable goals helps make CCTV
                                               systems more effective and can also reassure the public about its use.

                                               A CCTV Control Room




www.gao.gov/cgi-bin/getrpt?GAO-03-748.

To view the full report, including the scope
and methodology, click on the link above.
For more information, contact Rich Stana at
(202) 512-8777 or stanar@gao.gov.
Contents


Letter                                                                                   1
               Results in Brief                                                         3
               Background                                                               5
               MPDC and United States Park Police Implementation of CCTV               10
               MPDC and United States Park Police Officials Said that
                 Regulations and a Draft Policy Address Concerns                       17
               Experiences of Other CCTV Users in the United States and UK
                 Reveal Best Practices for Other Interested Locations                  22
               Concluding Observations                                                 30
               Agency Comments and Our Evaluation                                      31

Appendix I     Scope and Methodology                                                   33



Appendix II    Implementation of CCTV Systems in Selected
               U.S. Cities                                                             35



Appendix III   Implementation of CCTV Systems in the United
               Kingdom                                                                 37



Figures
               Figure 1: Key Aspects of a CCTV System                                   6
               Figure 2: CCTV Cameras Monitoring Public Spaces                         11
               Figure 3: A CCTV Control Room                                           14
               Figure 4: Scope of a CCTV Camera Surveillance Area                      18
               Figure 5: Depiction of a CCTV Sign                                      23
               Figure 6: Police Officer Monitoring a CCTV System                       26
               Figure 7: CCTV Monitor                                                  28




               Page i                                        GAO-03-748 Video Surveillance
Abbreviations

ABA               American Bar Association
ACLU              American Civil Liberties Union
CCTV              closed-circuit television
EPIC              Electronic Privacy Information Center
IACP              International Association of Chiefs of Police
MPDC              Metropolitan Police Department of the District of Columbia
SIA               Security Industry Association
UK                United Kingdom




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Page ii                                                    GAO-03-748 Video Surveillance
United States General Accounting Office
Washington, DC 20548




                                   June 27, 2003

                                   The Honorable Thomas Davis
                                   Chairman
                                   Committee on Government Reform
                                   House of Representatives

                                   Dear Mr. Chairman:

                                   Surveillance video cameras have become a growing presence in the public
                                   arena over the past several decades in stores, civic buildings, and even on
                                   public streets. As part of this trend, law enforcement has increasingly used
                                   closed-circuit television (CCTV)—which involves a linked system of
                                   cameras able to be viewed and operated from a control room—as a tool
                                   for fighting crime. Police departments in the United States commonly use
                                   CCTV to, among other things, deter, detect, and investigate crime and
                                   control crowds. Since September 11, 2001, law enforcement has also
                                   begun to use CCTV to combat terrorism. In particular, both the
                                   Metropolitan Police Department of the District of Columbia (MPDC) and
                                   the National Park Service’s United States Park Police within the
                                   Department of the Interior have used CCTV systems to monitor certain
                                   public spaces1 under their jurisdictions in Washington, D.C. For example,
                                   the United States Park Police has responsibility for policing the area
                                   around the White House, the Franklin Delano Roosevelt Memorial, the
                                   Washington Monument, the Lincoln Memorial, the Jefferson Memorial, and
                                   the Vietnam Veterans War Memorial.

                                   CCTV use in public spaces and varying methods of implementation have
                                   raised concerns among critics of CCTV use. Specifically, civil liberties
                                   advocates have raised issues concerning CCTV’s potential impact on
                                   individual privacy as well as the potential for inappropriate use of CCTV
                                   systems and the mishandling of CCTV images. In addition, these advocates
                                   expressed concern about using the technology when its effectiveness for
                                   law enforcement use has not been proven. Civil liberties advocates
                                   propose that controls are needed to help ensure the protection of
                                   individual privacy and the proper use of CCTV systems. The American Bar



                                   1
                                    For this report, public spaces are defined as public parks, public streets, and
                                   commercial/business districts.



                                   Page 1                                                       GAO-03-748 Video Surveillance
    Association2 (ABA) and other organizations have developed guidelines for
    CCTV users that address some of the issues raised by civil liberties
    advocates through the use of management controls. These include
    developing written operating protocols, establishing supervision and
    training requirements, providing for public notification, and requiring
    periodic audits.

    This report responds to a request from former Representative
    Constance A. Morella in her capacity as Chair of the House Government
    Reform Subcommittee on the District of Columbia, asking us to examine
    several issues surrounding the use of CCTV to monitor public spaces. As
    discussed with your office, we are sending you this report because of your
    oversight responsibility for the District of Columbia. This report discusses:

•   How MPDC and the United States Park Police have implemented their
    CCTV systems.
•   How MPDC’s and the United States Park Police’s management controls
    respond to issues raised regarding individual privacy and the use of CCTV.
•   Whether the experiences of other CCTV users in the United States and the
    United Kingdom (UK) offer useful insights for MPDC and the United States
    Park Police regarding the issues that have been raised.

    To determine how MPDC and the United States Park Police have
    implemented their CCTV systems, we interviewed MPDC and United
    States Park Police officials and reviewed relevant laws, regulations,
    policies, and other documents. To determine how MPDC’s and the United
    States Park Police’s management controls responded to issues raised
    regarding the use of CCTV, we interviewed MPDC and United States Park
    Police officials. We did not evaluate or test compliance with MPDC’s or
    the United States Park Police’s management controls. We also interviewed
    representatives from the ABA, the American Civil Liberties Union3
    (ACLU), the Electronic Privacy Information Center4 (EPIC), the



    2
     ABA is a nationwide organization that, among other things, provides law school
    accreditation, programs to assist lawyers and judges in their work, and initiatives to
    improve the legal system for the public. ABA published guidance for law enforcement’s use
    of CCTV and other technologies in its “Standards for Criminal Justice: Electronic
    Surveillance, Part B: Technologically-Assisted Physical Surveillance.”
    3
     ACLU is a nationwide, nonpartisan organization whose stated mission is to defend the
    principles of liberty and equality embodied in the Bill of Rights.
    4
     EPIC is a public interest research center located in Washington, D.C. It was established in
    1994 to, among other things, focus public attention on emerging civil liberties issues.



    Page 2                                                      GAO-03-748 Video Surveillance
                   International Association of Chiefs of Police5 (IACP), and the Security
                   Industry Association6 (SIA) to obtain their views on the use of CCTV.

                   To learn about the experiences of CCTV users in other U.S. cities, we
                   obtained documentation and interviewed officials and representatives in
                   four U.S. locations—Baltimore, Maryland; Tampa, Florida; Columbia,
                   South Carolina; and Virginia Beach, Virginia. These locations were
                   selected for one or more of the following reasons: they had used CCTV for
                   some time, had recently initiated the use of CCTV, were located close to
                   D.C., or were using other technology in conjunction with CCTV. In
                   addition, we visited the UK—a country that has used CCTV extensively to
                   address crime and terrorism. We toured the control rooms and observed
                   the operations of CCTV systems in some U.S. cities and in all of the UK
                   locations visited. See appendix I for a more detailed discussion of our
                   scope and methodology.

                   We performed our audit work from August 2002 to May 2003 in
                   Washington, D.C., and the selected locations mentioned earlier, in
                   accordance with generally accepted government auditing standards. We
                   requested comments on a draft of this report from MPDC and the
                   Department of the Interior, and their comments have been incorporated as
                   appropriate.


                   MPDC and the United States Park Police have their own CCTV systems
Results in Brief   implemented independently of each other. The purpose of MPDC’s CCTV
                   system is to facilitate crowd management and allocate police resources
                   during major public events and demonstrations with the intended purpose
                   of deterring crime such as destruction of property. The system is also used
                   to coordinate traffic control on an as-needed basis. Finally, the system is
                   used during exigent circumstances. In this regard, a senior MPDC official
                   said that CCTV has the dual purpose of helping to combat terrorism. The
                   D.C. City Council is considering whether CCTV might be used to fight
                   crime in neighborhoods. According to its regulations, MPDC’s system is to



                   5
                    IACP is a nonprofit membership organization of police executives whose leadership
                   consists of the operating chief executives of international, federal, state, and local agencies
                   of all sizes.
                   6
                    SIA is an international trade association whose mission is to, among other things,
                   effectively and responsibly promote the use of electronic security equipment in
                   commercial, institutional, commercial, governmental, and residential markets.




                   Page 3                                                        GAO-03-748 Video Surveillance
be operated on a limited basis during certain events such as major
demonstrations or exigent circumstances such as when the Department of
Homeland Security’s national threat level is increased to high alert (code
orange). MPDC obtained public comments on its implementation of CCTV.
In contrast, the United States Park Police states that CCTV is to be used to
counter terrorism but recognizes that it can be used to deter and detect
crime as well. The United States Park Police is operating its system on a
continuous basis. The United States Park Police has not obtained public
input on the implementation of its CCTV system; however, it is considering
doing so. MPDC has disclosed the locations of its cameras to the public,
whereas the United States Park Police has chosen not to do so because of
concerns about vandalism and concerns that individuals may attempt to
defeat the system. For civil liberty advocates concerned about CCTV use,
the unpredictability of how MPDC and the United States Park Police might
use their CCTV systems, where it might be used, and when it might be
used, contribute to their uneasiness about its use and a desire for controls
on its use.

MPDC has adopted regulations, and the United States Park Police is in the
process of developing a policy that includes management controls for
operating their CCTV systems. According to officials from both police
forces, they incorporated suggestions from guidelines published by the
ABA, IACP, or SIA when developing their regulations and policies. MPDC’s
regulations and the United States Park Police’s proposed policy include
management controls such as providing for training and periodic audits to
address concerns raised about improper use of CCTV systems. In addition,
MPDC has received feedback from the public on its regulations. The ABA
reviewed the draft regulations and indicated that it complies with the
ABA’s standards. However, a nonprofit scholarship and advocacy
organization called the Constitution Project also reviewed MPDC’s
regulations and concluded that the regulations lacked clarity and
specificity in some areas, such as training of CCTV operators. The United
States Park Police’s policy is in draft form and has not been reviewed
outside of the Department of the Interior.

The experiences of CCTV users in the UK and the selected U.S. cities
revealed best practices regarding the implementation and use of CCTV.
For example, UK and U.S. officials considered providing training and
conducting audits helpful to ensuring proper use of CCTV. Because of
their extensive use of CCTV, UK officials were able to provide more
experiences from which to learn and could offer useful insights for CCTV
use. Officials in the UK shared their views that (1) operating CCTV
systems in an open environment helps to alleviate privacy concerns;


Page 4                                           GAO-03-748 Video Surveillance
             (2) having uniform standards helps to reassure the public that safeguards
             are in place when utilizing CCTV and provides CCTV operators guidance
             for proper use; and (3) establishing clear, realistic, and measurable goals
             helps make CCTV systems more effective and can also reassure the public
             about its use. Clear and measurable goals identify the problems to be
             addressed by CCTV and can include a range of measures to determine
             whether goals have been achieved, such as the change in crime levels or
             the change in public attitudes about crime. Researchers and others
             recognize the importance of measuring effectiveness to justify the
             potential impact on individuals’ civil liberties and the costs associated
             with its use. At the same time, most CCTV users have not statistically
             measured the effectiveness of their CCTV systems and could only provide
             anecdotal evidence to demonstrate its effectiveness. CCTV users both in
             the UK and the selected U.S. cities told us that the effectiveness of CCTV is
             difficult to measure.

             We provided a draft of this report to and received comments from officials
             representing MPDC and the Department of the Interior. Officials from both
             departments generally agreed with the report and our presentation of
             information regarding their CCTV use. The Department of the Interior
             provided technical comments, which were included as appropriate. MPDC
             had no technical corrections.

             CCTV is a visual surveillance technology designed for monitoring a variety
Background   of environments and activities. CCTV systems typically involve a dedicated
             communications link between cameras and monitors. Digital camera and
             storage technologies are rapidly replacing traditional analog systems. A
             CCTV system involves a linked system of cameras able to be viewed and
             operated from a control room.




             Page 5                                            GAO-03-748 Video Surveillance
Figure 1: Key Aspects of a CCTV System


      Police officer                            Monitor                                                                           Public space




                                                                                Cable
                                                                                             CCTV Camera



Source: Tampa Police Department, Lachlan Cranswick, and GAO.



                                                               CCTV systems have evolved considerably over time and tend to fall into
                                                               three different generations. The first generation consisted of wide-angle,
                                                               fixed cameras (referred to as shoe boxes) that were targeted to crime
                                                               hotspots. The second generation consisted of cameras that could be
                                                               moved using a joystick in the control center focused on specific events or
                                                               people, zooming in for closer scrutiny. The third generation uses both
                                                               types of cameras with the additional capabilities to include software such
                                                               as facial recognition or license plate recognition.7 Relatively new features
                                                               in CCTV technology that enhance its power and scope include night vision
                                                               cameras, computer-assisted operations, and motion detectors. A camera
                                                               that is integrated with a motion detection system would, for example,
                                                               enable alerted law enforcement staff in a control room to remotely
                                                               investigate potential security incidents such as a terrorist placing a
                                                               package in an isolated location. Most CCTV systems are actively
                                                               monitored by security or law enforcement personnel in a centralized
                                                               setting, or they can be passively taped for future viewing if needed (such
                                                               as in the event of a robbery).

                                                               The private sector began using CCTV in the early 1960s, first in banks, and
                                                               later in commercial buildings. By the 1970s, CCTV was deployed in
                                                               hospitals, all-night convenience stores, and many other commercial areas.


                                                               7
                                                                Facial recognition technology identifies people by the sections of the face that are less
                                                               susceptible to alteration-the upper outlines of the eye sockets, the areas around the cheek-
                                                               bones, the sides of the mouth. Systems using this technology capture facial images from
                                                               video cameras and generate templates for comparing a live facial scan to a stored template.
                                                               License plate recognition software recognizes vehicle shape and ‘looks’ for a license plate.
                                                               If the license plate number is located in a centralized database, the CCTV system triggers
                                                               an alarm for appropriate personnel to take action. At the time of our review, MPDC and the
                                                               United States Park Police did not use either of these technologies.




                                                               Page 6                                                      GAO-03-748 Video Surveillance
The private sector also began to use CCTV in retail stores to monitor for
shoplifters and in hotels to help secure the safety of their guests. CCTV
technology advanced during the 1980s with the introduction of video
recorders, and even more in the 1990s with the introduction of digital
technology. CCTV is also used in public safety-related applications across
the United States, including traffic control, special events, public
transportation, and public schools.

CCTV use by law enforcement to fight crime and terrorism is an evolving
application of the technology. According to a number of reports, CCTV can
benefit law enforcement in many ways. A survey of law enforcement
agencies conducted by the IACP found that CCTV was useful in areas such
as investigative assistance and evidence gathering. The survey identified
other law enforcement benefits from CCTV use such as reducing time in
court for officers, protecting police officers against claims of police
misconduct, and using recorded images to train officers. A report by
RAND8 noted that proponents of video and similar types of surveillance
claim that it prevents crime by deterrence, especially when overt
surveillance activities remind potential criminals of police presence and
observation. The same report also states that, if an area under surveillance
becomes a crime scene, the surveillance can both alert police to the need
for an operational response and/or provide evidence for subsequent
criminal investigation and prosecution. A study commissioned by the SIA
also stated that CCTV has the ability to enhance law enforcement
capabilities by enabling officers to be deployed in areas that require more
traditional police work (such as foot patrols where officers can interact
with individuals), enabling the CCTV cameras to be used for general
surveillance.

In the context of law enforcement surveillance activities, a common
conception of privacy stems from criminal cases interpreting the Fourth
Amendment of the Constitution. The Fourth Amendment protects people
from unreasonable searches and seizures. According to the Supreme
Court, if the person under surveillance has a reasonable expectation of
privacy, the Fourth Amendment applies, and a warrant is generally
required to conduct a lawful search. Conversely, if the person under
surveillance does not have a reasonable expectation of privacy, the Fourth
Amendment does not apply, and no warrant is required for police



8
 RAND is a nonprofit institution that helps improve policy and decision-making through
research and analysis.




Page 7                                                    GAO-03-748 Video Surveillance
surveillance.9 Applying these principles, the 10th Circuit Court of Appeals
upheld the use of surveillance cameras placed on a public street without a
warrant on grounds that “activity a person knowingly exposes to the
public is not a subject of Fourth Amendment protection, and thus, is not
constitutionally protected from observation.”10

While there is generally no reasonable expectation of privacy under the
Fourth Amendment for activities visible to the public, the ACLU and EPIC
have argued that the use of surveillance systems to monitor public spaces
may nevertheless infringe upon freedom of expression under the First
Amendment. There does not appear to be any federal case law interpreting
whether police use of video surveillance devices may infringe upon First
Amendment rights. However, ACLU and EPIC believe that CCTV might
“chill” protesters from demonstrating in public spaces such as on the
National Mall and elsewhere in D.C. knowing that their images might be
captured on police recordings.11 There is also concern that CCTV cameras
equipped with enhanced features, such as zoom capabilities, may give
police the ability to read and record the print on political fliers being
distributed in public places and to identify individuals engaged in political
speech, which, in their view, undercuts the ability of citizens to engage in
anonymous free speech.12




9
See Katz v. United States, 389 U.S. 347, 360-61 (1967) (Harlan, J., concurring).
10
  United States v. Jackson, 213 F.3d 1269, 1281 (10th Cir. 2000), remanded for further
consideration of the sentence imposed, 531 U.S. 1033 (2000). On remand, the 10th Circuit
upheld the prior decision except with respect to the sentencing issue. United States v.
Jackson, 240 F.3d 1245, 1247 n.2 (10th Cir. 2001).
11
  Although this case did not involve police use of video surveillance technology, the
Supreme Court in Laird v. Tatum, 408 U.S. 1, 10 (1972) held that protesters’ First
Amendment rights could not be chilled by “the mere existence, without more, of a
governmental investigative and data-gathering activity.” The plaintiffs in Laird were
political activists, who alleged that the Department of the Army’s surveillance activities
deterred them from exercising their First Amendment rights. The Supreme Court held that
the plaintiffs lacked standing to sue because their alleged injury was too speculative,
arising not from any specific action taken against them, but merely from their knowledge
that the Army was engaged in surveillance activities.
12
  A ban on anonymous free speech was struck down in McIntyre v. Ohio Elections
Commission, 514 U.S. 334 (1995). In that case, the Supreme Court declared
unconstitutional an Ohio election law requiring the names and addresses of authors to be
printed on political leaflets. Citing a longstanding tradition of anonymous free speech, the
Court held that there was no overriding state interest to require the authors to identify
themselves.




Page 8                                                       GAO-03-748 Video Surveillance
ACLU and EPIC officials said that they would like to see controls in place
to help guard against improper use of CCTV systems and the mishandling
of CCTV images. In addition, ACLU officials said that controls directing
the use of CCTV should contain specific provisions for protecting CCTV
images that include whether CCTV images are being recorded, under what
conditions, and how long the recordings are retained, as well as criteria
for access to CCTV images by the government or the public. An EPIC
official also said that controls should address access, storage, and
disclosure of records.

In the UK, CCTV and video surveillance have been used extensively. As of
2002, about 75 cities were using CCTV to monitor urban centers, and
approximately 95 percent of all local governments were considering its
use as a law enforcement tool. In 1990, according to the UK Home Office,13
the UK had approximately three CCTV systems operated by local
governments comprised of about 100 cameras. By the end of 2002, Home
Office officials estimated that the UK had approximately 500 CCTV
systems operated by local governments comprised of about 40,000
cameras. Nonlaw enforcement staff generally operate the CCTV systems in
the locations we visited in the UK. In most cases, the systems were set up
to address street-type crimes such as robbery, car theft, harassment, and
public drunkenness. The UK CCTV systems that we observed had control
rooms that were operational 24 hours per day, 7 days per week, and all
maintained digitally recorded images. The UK Home Office provided
funding for 684 CCTV systems as of October 2002, though not all were
operational at the time. Home Office officials said that the level of funding
per location has ranged from about $50,000 to $12 million to implement
CCTV in town centers, parking garages, and residential areas.

During the 107th Congress, a Senate bill was introduced that would have
established a commission to evaluate the use of investigative and
surveillance technologies, including surveillance cameras, to meet law
enforcement and national security needs in the manner that best preserves
individual privacy.14 Under the proposed legislation, the commission was
to investigate and report on standards for using, selecting, and operating
such technologies and to make recommendations for legislation or
administrative actions, as appropriate. However, the bill was not enacted.


13
 The Home Office is the governmental department responsible for internal affairs in
England and Wales.
14
 S. 2846, 107th Cong. (2002).




Page 9                                                    GAO-03-748 Video Surveillance
                     MPDC and the United States Park Police have implemented their CCTV
MPDC and United      systems with varying purposes and guiding protocols. The purposes of
States Park Police   MPDC’s and the United States Park Police’s CCTV systems differ;
                     however, both entities have installed cameras in locations that are at high
Implementation of    risk for terrorist attacks. When the Department of Homeland Security’s
CCTV                 national threat level was increased to high alert (code orange), MPDC and
                     the United States Park Police utilized CCTV on a continuous basis. Both
                     MPDC and the United States Park Police view their CCTV systems from
                     secure control rooms, and each entity’s CCTV cameras have enhanced
                     features, such as zoom capabilities. MPDC, acting under D.C. law, has
                     issued regulations pursuant to D.C. statute that provide operating
                     protocols to govern its use of CCTV, whereas the United States Park
                     Police’s use of CCTV is not specifically governed by any federal law or
                     regulation. However, the United States Park Police is in the process of
                     developing a policy applicable to its use of CCTV.




                     Page 10                                          GAO-03-748 Video Surveillance
Figure 2: CCTV Cameras Monitoring Public Spaces




Page 11                                           GAO-03-748 Video Surveillance
Page 12   GAO-03-748 Video Surveillance
MPDC Operates CCTV on   MPDC’s CCTV system is generally intended to help manage public
a Limited Basis         resources (such as police officers) during major public events and
                        demonstrations and to coordinate traffic control on an as-needed basis. In
                        addition to these purposes, the system may be utilized during exigent
                        circumstances (e.g., periods of heightened alert for terrorism) as
                        designated by the police chief. While the purpose of MPDC’s CCTV system
                        is to manage public resources and to control traffic, it could be used for
                        monitoring crime as well. For example, although CCTV can be used to
                        deploy police resources in order to maintain crowd control, the implied
                        reasoning for deploying officers to maintain control would be to deter or
                        prevent criminal activity, such as looting and rioting.

                        MPDC has used CCTV cameras for events such as the Fourth of July
                        celebration in 2002 and antiwar demonstrations in 2003. According to a
                        senior MPDC official, the CCTV cameras are not operational on a 24-hour
                        basis; they are activated only during certain events and are turned off
                        when the event ends. For example, the Chief of Police said that political
                        demonstrations resulted in MPDC activating and deactivating the cameras
                        only to reactivate them again when the Department of Homeland Security
                        increased the national threat level to high alert (code orange).

                        MPDC has increased its CCTV system operations over time and has the
                        capability to expand its operations by accessing other CCTV systems. A
                        senior MPDC official said that MPDC’s CCTV system had been increased
                        from two cameras in April 2000, to 14 cameras with pan, tilt, and zoom
                        capabilities. The cameras are monitored from a control room called the
                        Joint Operations Command Center15 located within MPDC’s headquarters.
                        According to the MPDC Chief of Police, the locations of the cameras
                        throughout D.C. were chosen because they were thought to be locations
                        that were at the highest risk for terrorism. MPDC can obtain real-time
                        video images from other D.C. agencies, including the District of Columbia
                        Public Schools. These agencies must first give MPDC access to their
                        camera images. In addition, MPDC can access real-time video images from
                        certain private entities in the D.C. metropolitan area, although a D.C.
                        official said that MPDC has not been doing so. MPDC’s CCTV cameras
                        were purchased and maintained with city funds.



                        15
                          The Joint Operations Command Center is a secure facility operated by MPDC, but may
                        include staff from other federal, regional, state, and local law enforcement agencies during
                        joint operations. The Joint Operations Command Center is a part of MPDC’s Synchronized
                        Operations Command Complex.




                        Page 13                                                     GAO-03-748 Video Surveillance
                         Figure 3: A CCTV Control Room




MPDC Has Regulations     MPDC drafted regulations and an implementing general order on the use
That Govern Its Use of   of CCTV in June 2002. These documents were made available to the ABA
CCTV                     for approval on their contents to help ensure that they reflected ABA
                         standards. MPDC incorporated ABA’s comments when formulating
                         proposed rules to govern the use of its CCTV system, and the Mayor
                         presented the proposed rules to the D.C. City Council. At a hearing before
                         the D.C. City Council, witnesses testified that the use of CCTV should be
                         legislated by the D.C. Council before any further consideration of MPDC’s
                         proposed rules. The council subsequently enacted a D.C. statute,16 which
                         required MPDC to issue CCTV regulations subject to the approval of the
                         D.C. City Council. MPDC’s proposed regulations were subsequently
                         published in the D.C. Register for public comment on September 6, 2002.17


                         16
                          D.C. Code 5-133.19.
                         17
                          49 D.C. Reg. 8465 (Sept. 6, 2002).



                         Page 14                                         GAO-03-748 Video Surveillance
                            The D.C. Council passed a resolution approving the proposed regulations
                            on November 7, 2002. The final regulations set out the above-mentioned
                            purposes of D.C.’s CCTV system and provide operating protocols for its
                            use.18

                            However, the D.C. City Council plans to consider CCTV legislation during
                            the current council period that would, if enacted, impose additional
                            requirements on the use of CCTV (such as a requirement to obtain a court
                            order to use video surveillance technology with certain telescopic zoom
                            capabilities) and would require MPDC and other D.C. government
                            agencies to promulgate regulations consistent with the legislation.19 In
                            addition, the bill would authorize a pilot project for the purpose of
                            evaluating the effectiveness of video surveillance as a crime prevention
                            tool. In particular, the bill would allow the installation of video
                            surveillance technology in two D.C. neighborhoods for a period not to
                            exceed 1 year to assess whether it was an effective crime prevention tool.
                            D.C. residents, neighborhood organizations, and advocacy groups
                            provided testimony both for and against MPDC’s use of CCTV during
                            public hearings held in December 2002 on the proposed bill.


United States Park Police   The United States Park Police is installing CCTV cameras to combat
Operating CCTV on a         terrorism and to further law enforcement and public safety objectives.
Continuous Basis            According to the Chief of the United States Park Police, the United States
                            Park Police’s CCTV system is to operate cameras located along the
                            Monumental Core. The United States Park Police used CCTV for a single
                            day on July 4, 2002, during the celebrations on the National Mall, and then
                            the system was turned off pending completion of system implementation
                            and the development of a policy. The United States Park Police developed
                            a one-page policy for its use of CCTV on this day, and this policy became
                            inactive at the end of the day. According to the Chief, the United States
                            Park Police initially planned to wait until its policy was complete to
                            resume the operation of its CCTV system; however, they used the cameras
                            during large-scale demonstrations on the National Mall and when the
                            Department of Homeland Security increased the national threat level to
                            high alert (code orange). Subsequently, officials said that the United States
                            Park Police’s CCTV system has been used continuously since March 2003,


                            18
                             49 D.C. Reg. 11443 (Dec. 20, 2002) (to be codified at D.C. Mun. Regs. tit. 24, ch. 25).
                            19
                             D.C. Bill 15-0033, “Limited Authorization of Video Surveillance and Privacy Protection Act
                            of 2003.”




                            Page 15                                                       GAO-03-748 Video Surveillance
                            following a security-related incident on the National Mall. The CCTV
                            system was operated under a draft policy each time it was activated. The
                            United States Park Police staff monitors the cameras from a secured,
                            controlled access United States Park Police facility. According to the
                            Chief, as of May 2003, the United States Park Police continues to add
                            cameras to its system and is operating under the auspices of a draft policy.
                            The United States Park Police does not plan to publicly disclose the exact
                            locations or the number of cameras used in their system due to their
                            concerns that individuals could use this information to defeat the system
                            or vandalize the cameras. According to United States Park Police officials,
                            the decision to post signs indicating that CCTV is in use is currently under
                            evaluation, and a decision had not been made at the time of our review.

                            Some of the United States Park Police’s cameras have pan, tilt, and zoom
                            capabilities and others have motion detecting capabilities. The Chief of the
                            United States Park Police said that their choice of CCTV equipment was
                            based on what was determined to be the most appropriate technology at
                            the time. According to the Chief, the United States Park Police does not
                            have plans to network its cameras to other agencies such as MPDC,
                            though the cameras are equipped to do so. The Chief said that, in addition
                            to viewing its own CCTV monitors, the Park Police is authorized to view
                            MPDC’s monitors in MPDC’s Joint Operations Command Center. The
                            United States Park Police’s CCTV system is being purchased with
                            appropriated funds at a cost of approximately $2.037 million.


United States Park Police   The United States Park Police’s use of CCTV is not specifically governed
Is Developing a Policy to   by any federal law or regulation. While there may be limitations protecting
Guide Its Use of CCTV       individuals against abuse of CCTV by federal law enforcement officers,
                            such limitations do not arise from federal laws or regulations specifically
                            addressing how federal law enforcement agencies are to use CCTV.20
                            However, the United States Park Police is in the process of developing a
                            CCTV policy. As of May 2003, the United States Park Police is in the
                            process of finalizing a draft policy that is to guide the use of its CCTV
                            system, and its policy has not been reviewed outside the Department of
                            the Interior. According to an Interior official, the United States Park Police
                            is not required to obtain public comment on its proposed CCTV policy;


                            20
                              As an example, individuals may be able to sue federal law enforcement officers for
                            conduct that violates a constitutional right, such as using CCTV without a warrant to peer
                            into private residences. Such lawsuits are commonly called Bivens actions. See Bivens v.
                            Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971).




                            Page 16                                                     GAO-03-748 Video Surveillance
                           however, it is considering providing the public an opportunity to
                           comment.


                           MPDC officials said that they had adopted regulations, and United States
MPDC and United            Park Police officials said that they were drafting a policy to address issues
States Park Police         raised by civil liberties advocates. Both the regulations and the draft policy
                           have incorporated management controls to address issues regarding
Officials Said that        individual privacy and the proper use of CCTV. Regarding the issue of
Regulations and a          CCTV effectiveness, MPDC and the United States Park Police both
                           maintained that CCTV is an effective law enforcement tool and that they
Draft Policy Address       plan to measure the effectiveness of their CCTV systems. However, both
Concerns                   entities are of the opinion that measuring CCTV effectiveness may be
                           difficult.



MPDC and United States     MPDC’s regulations and the United States Park Police’s draft policy
Park Police CCTV Privacy   address the protection of individual privacy in the following ways: MPDC’s
Policies                   regulations state that the CCTV cameras are to be used to observe
                           locations that are in public view where there is no reasonable expectation
                           of privacy. A senior MPDC official said that MPDC’s CCTV cameras are
                           equipped with software that blocks the viewing of private areas, such as
                           apartment windows and residential backyards. According to the Chief of
                           Police, the United States Park Police has taken a similar position. This
                           official said that they would focus their cameras on public park areas and
                           public activities where there is no constitutionally protected expectation
                           of privacy.




                           Page 17                                           GAO-03-748 Video Surveillance
Figure 4: Scope of a CCTV Camera Surveillance Area




MPDC and the United States Park Police both maintain that their CCTV
systems are to be operated in public spaces without infringing on
individuals’ First Amendment rights. MPDC’s regulations state that under
no circumstances is the CCTV system to be used for the purpose of
infringing on First Amendment rights. The regulations state that CCTV
operators are not to focus on hand bills or fliers that are being distributed
or carried pursuant to First Amendment rights. According to the Chief of
the United States Park Police, the department is also committed to
ensuring that individuals are able to freely exercise their First Amendment
rights. The United States Park Police’s draft policy states that CCTV
operators are not to target or focus on the faces of individuals engaging in
First Amendment protected activities unless there is an indication of a
criminal activity or threat to public safety. In addition, according to the
Chief, the United States Park Police’s draft CCTV policy strikes a balance
between providing safety for citizens and protecting the privacy of
demonstrators at various rallies and protests on the National Mall.




Page 18                                              GAO-03-748 Video Surveillance
MPDC and the United       MPDC and United States Park Police officials have in place or are putting
States Park Police CCTV   in place, respectively, management controls for operating their CCTV
Management Controls       systems and handling CCTV images. Specifically, MPDC’s regulations and
                          the United States Park Police’s draft policy address the need for
Address Proper Use of     appropriate supervision to protect against inappropriate use of their
CCTV Systems              systems and establish procedures for appropriate access to and handling
                          of CCTV images. According to MPDC’s regulations, only the Chief of
                          Police is to authorize use of the CCTV system. This authorization must be
                          in writing except in situations involving exigent circumstances or
                          demonstration purposes. In addition, an official in the rank of Lieutenant
                          or above is to be present at all times during system activation and usage
                          and is to supervise and monitor the CCTV activities. Only certified
                          operators are to be allowed to operate the system. MPDC’s regulations
                          state that every system activation is to be documented and that the
                          activation information is to include the disposition of any observed
                          incidents, a copy of any written authorizations pertaining to each
                          activation, the names of any individuals activating the system, and
                          documentation of when activation began and ended. The United States
                          Park Police’s draft policy states that the supervisory official assigned to, or
                          responsible for, the control room is to monitor the activities of assigned
                          personnel to ensure full compliance with the policy statement. All CCTV
                          system operators are to be trained and supervised while operating the
                          system. To ensure compliance with its regulations, MPDC’s regulations
                          state that audits are to be conducted by its Office of Professional
                          Responsibility on at least a quarterly basis. According to a senior MPDC
                          official, a compliance audit had been completed recently and found that
                          the system was in full compliance with MPDC’s regulations. Similarly, the
                          Chief of the United States Park Police said that random audits are to be
                          performed to ensure that the CCTV system is used properly.

                          Furthermore, MPDC’s regulations state that unauthorized use or misuse of
                          the CCTV system by operators is subject to criminal prosecution and/or
                          administrative sanctions, including termination. A policy drafted by the
                          United States Park Police states that their CCTV cameras are to be
                          operated and supervised by the United States Park Police in a professional
                          manner and only to further legitimate law enforcement and public safety
                          objectives. In addition, the United States Park Police draft policy states
                          that no person is to be targeted or monitored merely because of race,
                          religion, gender, or political affiliation. Further, the Chief of the United
                          States Park Police said that the United States Park Police does not plan to
                          make use of the zoom capability unless suspicious activity is detected.




                          Page 19                                            GAO-03-748 Video Surveillance
MPDC and the United States Park Police have addressed data collection
and management issues by restricting access to their CCTV systems and
outlining the security procedures for maintaining recorded images. MPDC
houses its CCTV system in a secure control room, which is protected
against unauthorized access by the use of bar-coded identification cards
and a palm-print recognition system. Only federal agencies with a valid
interest in viewing the cameras, such as the Federal Bureau of
Investigation and the United States Park Police, are to gain access to the
CCTV control room. According to the Chief of Police, agencies that have
access to the Joint Operations Command Center are required to sign a
memorandum of understanding stating that they will comply with MPDC
regulations. According to MPDC’s regulations, the Chief of Police is to
issue written authorization prior to recording any CCTV images, except in
exigent circumstances or when recording is being done pursuant to a
court order. The regulations also require that every recording is to be
documented in the same manner as every system activation and that all
recorded CCTV footage is to be secured. The regulations further state that
recordings will be retained for 10 business days and then destroyed, unless
they are to be retained as evidence in a criminal case, a civil suit against
MPDC, or for training purposes, as authorized in writing by the Chief of
Police. Recordings retained for criminal or civil proceedings must be
secured as evidence; recordings retained for training purposes may only
be retained for as long as they are actively used.

United States Park Police draft policy states that CCTV images are to be
transmitted through secured channels, and monitoring of the CCTV
cameras is to be done from a controlled facility. Access to the controlled
facility, as well as access to live or recorded CCTV images is to be limited
to authorized personnel, for law enforcement and public safety purposes,
or for civil litigation and disciplinary purposes. In order for another law
enforcement agency to gain access to the recorded CCTV images, the
Chief of the United States Park Police opined that there would need to be
a clear nexus with a crime. Additionally, according to the draft policy,
recordings are to be retained for no more than 6 months and then
destroyed unless needed as evidence for a documented criminal incident.
The draft policy also states that in the event that a video recording needs
to be retained for more than 6 months, the reason, length of time, and
chain of custody is to be documented.




Page 20                                           GAO-03-748 Video Surveillance
MPDC and the United         A D.C. official said that the effectiveness of MPDC’s CCTV system is
States Park Police          difficult to measure because of its limited use of the cameras. Further, the
Perceive Measuring the      Chief of Police said that crime statistics could not be used to evaluate the
                            effectiveness of the cameras since MPDC currently does not use the
Effectiveness of CCTV to    cameras specifically to detect crime. The regulations state that the general
be Difficult, but Plan to   purpose of the cameras is to help manage public resources during major
Develop Measures            public events and demonstrations and to coordinate traffic control. This
                            purpose reflects a mission of deterring crime and minimizing traffic
                            problems. Measuring deterrence can be difficult without a comparison
                            between similar areas with and without CCTV. Measuring CCTV
                            effectiveness may be further complicated by the use of other law
                            enforcement interventions such as improved lighting and notices about
                            CCTV. Thus, demonstrating a direct cause and effect relationship between
                            decreased crime and CCTV may not be easy to do.

                            MPDC’s CCTV regulations require MPDC to prepare an annual report that
                            includes, among other things, an evaluation of whether the cameras have
                            achieved their purposes as outlined in the regulations. According to a
                            senior MPDC official, an annual report has not been prepared to date
                            because the system has not been operational for one year. Although crime
                            control is not the stated purpose of MPDC’s CCTV system, an MPDC
                            official said that MPDC’s CCTV cameras have caught crimes. The official
                            provided an anecdotal example of the system’s effectiveness—the CCTV
                            cameras were activated for a high-profile sporting event and subsequently
                            caught some car thieves.

                            United States Park Police officials also said that it has been difficult to find
                            measures of effectiveness for such things as crime prevention related to
                            CCTV use. To measure effectiveness of their CCTV system, the Chief of the
                            United States Park Police said that once their system is activated, they
                            plan to track arrests made resulting from camera use.

                            Overall, both MPDC and the United States Park Police view CCTV as a
                            valuable complement to their other policing efforts. MPDC and United
                            States Park Police officials said that they have received positive feedback
                            from the community, including, in some cases, requests for more CCTV
                            cameras and in others, gratitude from residents for going the extra mile to
                            make them feel safe.


Public Feedback on          MPDC made its regulations available for public comment and held
MPDC’s Regulations          hearings regarding the operation of its CCTV system. At hearings, MPDC
                            received positive and constructive feedback regarding its CCTV


                            Page 21                                             GAO-03-748 Video Surveillance
                           regulations. MPDC also received positive feedback from the ABA
                           regarding its regulations. ABA reviewed MPDC’s draft regulations in
                           comparison with its published standards and concluded that MPDC’s
                           regulations comply with ABA’s standards on video surveillance.

                           Other feedback was less positive. The Constitution Project, a nonprofit
                           scholarship and advocacy organization, provided draft comments on
                           MPDC’s regulations and noted several areas that lacked clarity and
                           specificity. For example, the Constitution Project stated that
                           comprehensive training and instruction for CCTV operators is essential to
                           enable them to better navigate the line between appropriate investigation
                           and infringement of civil liberties, noting that there are no provisions in
                           MPDC’s regulations that detail what credentials and training are required
                           to obtain certification to operate the CCTV system.

                           The Constitution Project also commented, among other things, that posted
                           signs indicating the presence of CCTV cameras should contain contact
                           information of an independent entity that concerned residents can contact
                           should they believe that the cameras’ presence is invasive, unnecessary, or
                           utilized improperly. Further, the Constitution Project stated that the audit
                           provisions in MPDC’s regulations raise the larger question of whether the
                           entity conducting the audit is sufficiently independent to perform a
                           credible audit function.


                           Officials in the selected U.S. cities and in the UK shared with us practices
Experiences of Other       that they considered beneficial to help ensure proper and effective use of
CCTV Users in the          CCTV systems. Because of their extensive use of CCTV to deter, detect,
                           and investigate crime, the experiences from UK officials offered a greater
United States and UK       number of best practices than the selected U.S. cities, though models from
Reveal Best Practices      other countries are not always applicable to the United States. Like MPDC
                           and the United States Park Police, the UK and the selected cities have
for Other Interested       grappled with how to measure the effectiveness of their CCTV systems.
Locations
Public Notice Helps to     UK officials said that gaining acceptance of their CCTV systems was based
Address Privacy Concerns   on having honest, open, and fair communication between the community
                           and the authorities. CCTV users who managed the CCTV systems in the
                           UK said that obtaining buy-in from stakeholders such as the public, in
                           addition to operating the system in an open environment, was an
                           important factor in mitigating concerns about the use of CCTV. For
                           example, according to a UK official, one borough invited the public (and in



                           Page 22                                          GAO-03-748 Video Surveillance
                              some instances, former and suspected criminals) to tour its control room
                              to show them the reality of how the system is used to identify criminals.

                              Figure 5: Depiction of a CCTV Sign




                              Like MPDC and the United States Park Police, many of the selected U.S.
                              cities encountered concerns and skepticism by the ACLU and others
                              regarding their use of CCTV to monitor public spaces. In some cases, the
                              public has also voiced concerns about how CCTV may be used and
                              whether it might infringe upon their individual privacy. In response to the
                              privacy concerns, CCTV users in the selected U.S. cities have generally
                              provided citizens with notification of the intent to use CCTV and provided
                              avenues for the public to comment and provide feedback. Each city posted
                              signage that indicated that CCTV was in use. Also, CCTV users in some of
                              the selected cities allowed the public to comment on aspects of the CCTV
                              system through community meetings and public hearings. Officials in one
                              city said that the public was also informed through a media campaign that
                              detailed the specifics of the CCTV system. The Chief of Police in one city
                              said that he had personally held conversations with residents to assure
                              them that the CCTV cameras would not compromise their privacy.


Having Standards Helps to     The UK government saw a need to establish controls over the use of CCTV
Alleviate Objections to the   systems in order to maintain public confidence. UK officials generally
Use of CCTV                   recognized the importance of having regulations in place to govern CCTV
                              systems, stating that having standards makes citizens feel more
                              comfortable and safe regarding how the system is being operated. CCTV


                              Page 23                                         GAO-03-748 Video Surveillance
standards were established through the Data Protection Act of 1998.21
Among other things, the standards addressed individual privacy issues in
relation to CCTV use. According to a UK official, there was no statutory
basis for systematic legal control of CCTV surveillance over public areas in
the UK until March 2000, when the Data Protection Act of 1998 was
implemented.

The Data Protection Act is the principal legislation that impacts the
operation of public space CCTV systems in the UK. Under the Data
Protection Act, the UK Information Commissioner22 issued a CCTV Code of
Practice to provide specific standards to CCTV operators on how to
comply with the act’s data handling principles. According to the UK
Information Commissioner, the Code of Practice has the dual purpose of
assisting CCTV operators to understand their legal obligations while also
reassuring the public of the safeguards that should be in place when
utilizing CCTV. The Code of Practice also indicates standards that are not
strict legal requirements, but represent good practice. UK Home Office
officials said that CCTV users follow the Code of Practice and comply with
the Data Protection Act of 1998 because they recognize that the act and
the code both help to alleviate objections to the use of CCTV.

For the selected U.S. cities, there were no state laws or regulations
specifically governing how state or local law enforcement officers were to
use CCTV systems to monitor public spaces. While there may be
limitations on law enforcement’s use of CCTV in these states, such
limitations do not stem from comprehensive state CCTV laws or
regulations.23 However, police departments in these cities generally had


21
  The Data Protection Act 1998, ch. 29 (Eng.) is available at
http://www.legislation.hmso.gov.uk/acts/acts1998/19980029.htm. The CCTV standards
issued under the Data Protection Act, called the CCTV Code of Practice, can be accessed at
http://www.dataprotection.gov.uk/dpr/dpdoc.nsf/0/db76232b37b5bb648025691900413c9d?O
penDocument
22
  The UK Information Commissioner is an independent supervisory authority reporting
directly to the U.K. Parliament. The Commissioner enforces and oversees the Data
Protection Act of 1998. The Commissioner has a range of duties including the promotion of
good information handling and the encouragement of codes of practice for data controllers,
that is, anyone who decides how and why personal data, (information about identifiable,
living individuals) are processed.
23
  For example, state “Peeping Tom” statutes provide criminal sanctions for unauthorized
spying or peeping into private places. These statutes might apply to CCTV surveillance that
lacks a valid law enforcement purpose, is voyeuristic in nature, and occurs in a private
place as defined by the statute. See, e.g., Fla. Stat. 810.14; Md. Code Ann., Crim. Law
3-902(b)(c); S.C. Code Ann. 16-17-470; Va. Code Ann. 18.2-130.



Page 24                                                    GAO-03-748 Video Surveillance
policies, which varied in detail and in content, to govern the use of their
CCTV systems. Organizations, including the ABA, IACP, and SIA, have
developed standards and guidelines that address privacy issues and
controls on CCTV use. ABA saw a need to develop standards in order to
help ensure that law enforcement agencies are aware of all the relevant
considerations with regard to CCTV use and to prompt these agencies to
create their own internal guidelines for the use of CCTV technology.
According to the IACP and SIA they collaborated to produce guidelines
because, despite the prevalence of CCTV use on national and local levels,
there were no consistent policies or procedures guiding the use of CCTV
systems. The IACP and SIA recommend that law enforcement agencies
and public safety officials adopt some or all of their guidelines to assist in
their use of CCTV.




Page 25                                            GAO-03-748 Video Surveillance
                          Figure 6: Police Officer Monitoring a CCTV System




Clear Goals and Purpose   To help ensure that CCTV systems are used effectively, some CCTV users
Help Ensure Appropriate   in the UK indicated that it is important to have a plan prior to the
Use and Alleviate         implementation of the CCTV system that should include clear, realistic,
                          and measurable goals for the CCTV system, as well as how CCTV might
Concerns Raised           address the goals. For example, clear goals would include, among other
                          things, identifying the highest-priority problems to be addressed by the
                          system, problem locations, and what is to be observed. UK officials also
                          said that matching the CCTV technology to the purpose and goals of the
                          system is a key factor in the effective use of CCTV. For example, if the
                          purpose of the CCTV system is to deter crime, CCTV users may not need
                          cameras that pan, tilt, and zoom. Rather, the CCTV users may determine
                          that viewing and/or recording activity from fixed cameras used to observe
                          broad areas is sufficient to meet their needs. However, if the purpose of
                          the CCTV system is to detect crime and intervene, a CCTV user may
                          consider continuously monitoring the CCTV cameras in order to be able to
                          quickly respond to certain incidents. Clear and measurable goals identify
                          the problems to be addressed by CCTV and can include a range of


                          Page 26                                             GAO-03-748 Video Surveillance
                            measures to determine whether goals have been achieved, such as the
                            change in crime levels or the change in public attitudes about crime.

                            CCTV users in the selected cities whose CCTV systems were fully
                            operational have been able to make the systems more effective and
                            respond to some privacy concerns by appropriately matching the
                            technology being used with the intended purpose. In one instance, a
                            representative said that the ACLU’s concerns were mitigated because they
                            installed cameras without enhanced features, such as zoom capabilities.
                            They said that limited monitoring of the CCTV images, along with the fact
                            that the cameras do not pan, tilt, or zoom limits the potential for the
                            invasion of individual privacy. In contrast, CCTV users in selected cities
                            that installed cameras that did pan, tilt, or zoom lessened their chances of
                            abuse by reducing the time spent visually monitoring the cameras. For
                            example, in two cities, CCTV users only monitored the cameras during
                            designated times or at designated events, such as Sunday nights preceding
                            Monday holidays in a busy entertainment district. Officials in one of the
                            two cities said that the cameras were visually monitored everyday during
                            the tourist season and only monitored on weekends during the off-season.


Training and Audits May     UK officials said that they preferred a well-trained and professional staff to
Help to Ensure Proper Use   operate their CCTV system. According to one UK official, CCTV systems
of CCTV                     involve human interaction, requiring a manager and requiring training on
                            how to use the system. The official also said that the most successful
                            CCTV systems have good managers, good training, and sound procedures.

                            UK officials have identified performing audits of CCTV systems as a way to
                            hold CCTV users accountable for their actions and deter misuse while
                            operating CCTV systems. In one UK location, the activities of each CCTV
                            operator can be traced and audited via computer. In addition, a CCTV user
                            in the UK planned to employ the use of outside inspection teams to
                            perform random audits. The inspection teams are to have full authority to
                            observe how the CCTV system is being operated, although the CCTV
                            system observed had not yet performed any audits at the time of our visit.

                            In the selected U.S. cities, CCTV operators were trained to use CCTV by
                            the vendor providing the CCTV technology, or in some cases, by senior
                            management. For example, one city official said that the city’s CCTV
                            vendor would provide a minimum of approximately 2 to 3 days of training
                            on the use of the CCTV system in two parts: (1) command and control of
                            the system and (2) retrieving CCTV images from the system.



                            Page 27                                           GAO-03-748 Video Surveillance
                            CCTV users in selected U.S. cities also found audits to be helpful. To help
                            ensure that CCTV systems are not misused, an official in one city said that
                            the city formed a steering and audit committee comprised of citizens to
                            ensure that CCTV operations were in compliance with written procedures
                            in order to avoid misuse of the CCTV system. Another city official said that
                            committee members were allowed to visit the CCTV control room
                            whenever they wanted to review the recorded CCTV images. An official in
                            another city said that, while not an audit per se, they would review tapes
                            for inappropriate use of the cameras. For example, he said that review of
                            the tapes would allow them to determine if the officers monitoring the
                            cameras were focusing voyeuristically on women.

                            Figure 7: CCTV Monitor




Procedures for Handling     CCTV users in the United States and the UK have indicated that an
Data Helps to Ensure Data   important consideration in handling CCTV images is providing controls to
Are Used Appropriately      guard against abuse or misuse that enable CCTV users to operate CCTV
                            systems openly enough to gain public acceptability, but not so open as to



                            Page 28                                          GAO-03-748 Video Surveillance
                             invade individual privacy by releasing personal information to
                             unauthorized individuals. To address concerns related to the maintenance
                             and storage of data and individual access to data, policies developed by
                             the selected CCTV users covered various topics related to these issues. In
                             all of the selected U.S. cities and in the UK, CCTV images were retained for
                             a specific period of time, after which they were destroyed or reused,
                             unless they were retained for a bonafide law enforcement investigation. A
                             UK official said that citizens could obtain access to images of themselves;
                             however, they have to supply the exact date, time, and location where they
                             were recorded and the CCTV system blocks any other individuals in view.

                             In the UK, the Data Protection Act limits the way personal data are
                             processed in order to protect the privacy of individuals. The act requires
                             organizations that process personal data to comply with the eight statutory
                             principles of good data handling. These principles provide that personal
                             data must be: (1) fairly and lawfully processed in accordance with
                             applicable statutory conditions; (2) obtained and processed only for
                             specified, lawful purposes; (3) adequate, relevant, and not excessive in
                             relation to the purpose for which they are processed; (4) accurate; (5) not
                             kept longer than necessary; (6) processed in accordance with the data
                             subject’s rights; (7) secure; and (8) not transferred to countries outside the
                             European Economic Area without adequate protection for personal data.
                             The UK Information Commissioner, which is an independent supervisory
                             authority, enforces and oversees the act’s provisions.


Measuring Effectiveness of   Researchers and others stress the importance of measuring effectiveness
CCTV Perceived to be         of CCTV systems in order to justify costs and the potential impact on
Difficult, but Desirable     individuals’ civil liberties. There is general consensus among CCTV users,
                             privacy advocates, researchers, and CCTV industry groups that there are
                             few evaluations of the effectiveness of CCTV in reducing crime, and few
                             jurisdictions are keeping data to demonstrate that their CCTV systems are
                             effective.

                             A study undertaken on behalf of the Home Office, found mixed results for
                             the crime prevention effectiveness of CCTV. However, in October 2002, a
                             Home Office official said that the Home Office had provided funding for an
                             evaluation of effectiveness for 17 CCTV systems as part of a CCTV
                             initiative begun in 1999 for the implementation of 684 local government-
                             operated CCTV systems in the UK. The evaluations are to be completed in
                             November 2004. Home Office officials cautioned that using crime statistics
                             as a measure of effectiveness may not be a good measure. They said that
                             arrest rates might increase because the CCTV cameras view more criminal


                             Page 29                                           GAO-03-748 Video Surveillance
               activity and police are reacting to more reports originating from CCTV
               control centers. They also said that increased crime rates are not
               necessarily bad because it may mean more crimes are being reported that
               had previously gone undetected. Furthermore, one CCTV user in the UK
               said that the effectiveness of various CCTV systems could vary due to
               differences in CCTV supervisory personnel, training, and procedures.

               Officials in the UK provided anecdotal evidence of how CCTV cameras
               have been effective. For instance, officials in one UK location said that
               CCTV cameras have observed drug deals and fraudulent passports being
               passed. An official also gave an example of a little boy who was abducted
               from a shopping center. When the images on the CCTV tape were shown,
               officials could discern that the relative heights of the abductors indicated
               that two other children took the little boy. Another example involved
               bombings of several London pubs. Officials said that CCTV tapes were
               used to trace various pieces of evidence to identify the bomber. While the
               quality of the pub’s CCTV cameras was not good, the police were still able
               to use the images to locate the perpetrator by reviewing CCTV footage
               from various entities thereby tracking him on various videotapes until they
               were able to identify him and trace his whereabouts. For example, police
               used a store’s CCTV cameras to view the perpetrator buying equipment for
               the bombs. The official said that the police were convinced they would not
               have found the perpetrator without the CCTV cameras, since the bomber
               did not have a criminal record and there was no reason to suspect him.

               Most CCTV users in the selected U.S. cities whose systems were fully
               operational at the time of our visit did not statistically measure the
               effectiveness of their CCTV systems. They perceived it to be difficult to
               measure, although officials in the selected cities said that CCTV had been
               very effective in, among other things, detecting and investigating crime,
               monitoring areas for public safety, and enhancing security. Officials
               provided anecdotes to demonstrate their system’s effectiveness. For
               example, an official in one city said that the CCTV cameras filmed a drug
               transaction that resulted in an arrest.


               MPDC and the United States Park Police have implemented CCTV systems
Concluding     as part of their overall strategies to address crime and terrorism. While
Observations   specific uses and guiding protocols vary, both MPDC and the United States
               Park Police have installed cameras in areas that are high risk for terrorist
               attacks, view their systems from secure control rooms, and use cameras
               that have enhanced features, such as zoom capabilities. Measuring CCTV
               effectiveness is difficult because of the lack of comparisons of similar


               Page 30                                          GAO-03-748 Video Surveillance
                     areas with and without CCTV to show a direct cause and effect
                     relationship, and because it is often used in tandem with other law
                     enforcement tools. Nevertheless, both MPDC and the United States Park
                     Police plan to identify performance measures and evaluate effectiveness.

                     Civil liberties advocates have raised concerns about the protection of
                     privacy and the proper use of CCTV systems. MPDC has adopted
                     regulations and the United States Park Police is drafting a policy aimed at
                     incorporating management controls to address such issues. These include
                     developing written operating protocols, establishing supervision and
                     training requirements, providing for public notification, and requiring
                     system audits. It is too early to fully assess the sufficiency and
                     effectiveness of these controls.

                     The use of CCTV as a law enforcement tool is growing in the United States
                     and abroad. The experiences of CCTV users in the United States and the
                     UK can help guide other jurisdictions that are considering the use of this
                     law enforcement tool with regard to openness and community
                     involvement; uniform standards and management controls; and the
                     establishment of realistic, clear, and measurable performance goals.


                     In letters dated June 6, 2003, we requested comments on a draft of this
Agency Comments      report from MPDC and the Department of the Interior. Officials from both
and Our Evaluation   police departments generally agreed with the report and our presentation
                     of information regarding their CCTV use.

                     On June 23, 2003, the Department of the Interior provided written
                     technical comments, which were included as appropriate. In its comments,
                     Department of the Interior officials indicated that the United States Park
                     Police’s draft CCTV policy is in the final stages of review and is expected
                     to be finalized within 2 weeks of the date of its written comments. MPDC
                     had no technical corrections.


                     We are providing copies of this report to the Chairman and Ranking
                     Minority Members of the Senate Committee on Governmental Affairs, the
                     Senate and House Committees on Appropriations, and the Senate and
                     House Committees on the Judiciary. We are also providing copies of this
                     report to the Deputy Mayor for Public Safety and Justice for Washington,
                     D.C.; the Chief, Metropolitan Police Department of Washington, D.C.;
                     Secretary of the Department of the Interior; the Director of the National
                     Park Service; and the Chief, United States Park Police. Copies of this


                     Page 31                                          GAO-03-748 Video Surveillance
report will be made available to other interested parties. This report will
also be available on GAO’s Web site at http:/www.gao.gov.

If you have any questions, please contact me at (202) 512-8777 or by e-mail
at stanar@gao.gov or Linda Watson, Assistant Director, at (202) 512-8685
or by e-mail at watsonl@gao.gov. Key contributors to this report were
Leo Barbour, Christine Davis, Glenn Dubin, Michele Fejfar, Jamila Jones,
Nettie Richards, Amy Rosewarne, and Carrie Wilks.

Sincerely yours,



Richard M. Stana
Director, Homeland Security and Justice Issues




Page 32                                           GAO-03-748 Video Surveillance
             Appendix I: Scope and Methodology

Appendix I: Scope and Methodology


             To determine how the Metropolitan Police Department of the District of
             Columbia (MPDC) and the U.S. Department of the Interior’s United States
             Park Police have implemented their closed-circuit television (CCTV)
             systems, we interviewed officials from both agencies. We obtained and
             reviewed congressional hearing records related to the use of CCTV in
             Washington, D.C. We attended a D.C. City Council public hearing and
             obtained testimonies of officials and civilians who addressed the city
             council. At the United States Park Police, we obtained documents related
             to the use of CCTV as well as congressional testimony regarding their use
             of CCTV. We interviewed representatives from the American Bar
             Association (ABA), the American Civil Liberties Union (ACLU), the
             Electronic Privacy Information Center (EPIC), the International
             Association of Chiefs of Police (IACP), and the Security Industry
             Association (SIA) to obtain their views on the use of CCTV and obtained
             documentation from them regarding issues of concern to their
             organizations. In addition, we toured MPDC’s Joint Operations Command
             Center.

             To determine how MPDC and the United States Park Police have
             implemented management controls to respond to the issues surrounding
             their use of CCTV, we interviewed MPDC and United States Park Police
             officials and obtained and reviewed relevant laws, regulations, policies,
             and other documents. We also obtained and reviewed testimonies of
             officials and civilians at D.C. City Council public hearings and reviewed
             draft comments by the Constitution Project that critiqued MPDC’s
             regulations. We did not evaluate or test compliance with MPDC’s or the
             United States Park Police’s management controls.

             To learn about the experiences of other CCTV users in the United States
             and the United Kingdom (UK) we reviewed various studies and reports on
             CCTV use by law enforcement. We reviewed studies and reports by or for
             SIA, the California Research Bureau, RAND, and the UK Home Office,
             among others. We judgmentally selected four U.S. cities to visit and
             obtained information on their use of CCTV. The four cities selected were:
             Baltimore, Maryland, because of its proximity to D.C.;1 Columbia, South
             Carolina, because officials in this city were in the early stages of


             1
              We interviewed officials regarding the CCTV system implemented by the Downtown
             Partnership of Baltimore, a nonprofit corporation founded to, among other things, shape
             public policy and implement programs to strengthen the economic vitality of downtown
             Baltimore. The Baltimore City Police Department is a member of the Downtown
             Partnership of Baltimore.




             Page 33                                                   GAO-03-748 Video Surveillance
Appendix I: Scope and Methodology




implementing their CCTV system; and Tampa, Florida, and Virginia Beach,
Virginia, because their CCTV systems were equipped with facial
recognition software, and we wanted to include locations that were using
CCTV with advanced features. At each location, we interviewed officials
regarding privacy concerns, if any, that had resulted from their use of
CCTV, conducted research for any relevant state laws or regulations,
obtained and reviewed policies and other documentation related to the
operation of their systems, and inquired about whether they had measured
the effectiveness of their CCTV systems. In two cities, we toured the
control rooms from which the cameras were operated and monitored. We
visited the UK to learn from its experiences with CCTV use in a law
enforcement capacity. We met with UK Home Office officials and CCTV
users in the UK to determine what their experiences have been and
whether they measured the effectiveness of their systems. In the UK, we
interviewed government officials in the Home Office and CCTV users in
Newham and Westminster—boroughs of London—and the city of
Sheffield. We also observed CCTV operations in these locations. In
addition, we interviewed a representative of a private UK CCTV User
Group that provides assistance to CCTV users. To obtain a broader
perspective on privacy issues, we also interviewed a representative of
Privacy International2 in London.

We performed our audit work from July 2002 to May 2003 in Washington,
D.C., and other cited locations in accordance with generally accepted
government auditing standards.




2
 Privacy International is a human rights group that serves as a watchdog on surveillance by
governments and corporations.




Page 34                                                    GAO-03-748 Video Surveillance
              Appendix II: Implementation of CCTV

Appendix II: Implementation of CCTV
              Systems in Selected U.S. Cities



Systems in Selected U.S. Cities

              The following provides a summary of how each of the four cities we
              selected to visit has implemented their respective CCTV systems. The four
              cities were at different stages of development in implementing their
              systems and, generally were using CCTV to achieve different purposes.

              Baltimore, Maryland

              In Baltimore, a representative said that the city’s CCTV system was
              implemented in 1994 to deter crime. This system consisted of 64 CCTV
              cameras installed in the downtown area. The CCTV system was
              implemented to address property crimes and the community’s negative
              perception of safety. Both Baltimore City law enforcement personnel and
              staff from organizations and businesses that participate in the Downtown
              Partnership of Baltimore operate the system. The cameras did not have
              remote zoom capability and were generally not monitored. Recorded
              CCTV images are reviewed for investigative purposes if crimes occur.

              Columbia, South Carolina

              The Columbia Police Department implemented a pilot CCTV program in
              2002 prior to implementing a final CCTV system. The city’s final CCTV
              system was not fully implemented at the time of our review. The pilot
              CCTV system involved 3 fixed cameras located in residential areas and
              public parks. The Chief of Police in this city said that the city did not hold
              any formal hearings before the pilot CCTV system was implemented,
              although the use of CCTV was subject to a majority vote by the city
              council members. Although a city official said that the city purchased an
              additional 12 CCTV cameras for the final system, 3 pilot cameras were
              installed and operational at the time of our visit. Through the pilot
              program, a city official determined that in addition to monitoring the
              cameras from police headquarters, an added benefit would be to enable
              officers to monitor cameras from their police cars while on patrol. City
              officials decided to expand the CCTV viewing capability by linking the
              CCTV system to laptop computers which enabled officers to monitor
              CCTV images from their police squad cars.

              Tampa, Florida

              In Tampa, the police department first deployed CCTV in December 1997 in
              a busy entertainment district. An official said that the cameras were
              installed to address specific issues in the completion of the public safety
              mission, including management of large crowds and the adequate
              deployment of police personnel. The system was comprised of 36 CCTV


              Page 35                                            GAO-03-748 Video Surveillance
Appendix II: Implementation of CCTV
Systems in Selected U.S. Cities




cameras, all with the ability to pan, tilt, and zoom. The system was also
equipped with facial recognition software. The cameras were monitored
during certain nights of the week and during special events by police
personnel.

Virginia Beach, Virginia

Officials in Virginia Beach said that the police department began operating
the cameras in 1993 after an incident at a local event provided the impetus.
A city official said the CCTV cameras were used to deter, detect, and
investigate crime; monitor and enhance the security of certain areas; and
apprehend and prosecute suspected criminals and counter terrorism. The
system records images 24 hours per day, 7 days per week and is monitored
every day during the tourist season. During the nonvacation season, police
officers only monitored the cameras on weekends. According to officials,
the police department installed 10 CCTV cameras in a busy
oceanfront/business district. Each CCTV camera had the ability to pan, tilt,
and zoom. The system was also equipped with facial recognition software.




Page 36                                          GAO-03-748 Video Surveillance
              Appendix III: Implementation of CCTV

Appendix III: Implementation of CCTV
              Systems in the United Kingdom



Systems in the United Kingdom

              The United Kingdom (UK) locations that we visited operated CCTV
              systems that were similar in purpose and application. There were subtle
              variations in the purposes of each system; however, all CCTV systems we
              observed were implemented to control some aspect of crime.

              Newham, London

              In Newham, use of CCTV resulted from a public call to do something
              about the increasing crime rate. An official said that since the late 1960s
              and early 1970s, the borough had experienced an increase in street-type
              crime, which stemmed from structural unemployment and the existence of
              a known but relatively small criminal element. Most crime involved
              robbery, car theft, harassment, public drunkenness, drug trafficking, and
              hooliganism. Officials said that the public felt unsafe doing everyday
              things like walking down certain streets or shopping in certain areas.
              Therefore, officials said that it was easy to sell CCTV to the borough
              council, because the borough had one of the highest burglary and auto
              theft rates in the UK, and the public perceived CCTV to be an effective
              response to the crime. In 1997, Newham began using CCTV to address
              these crime problems.

              Officials said that about 10 uniformed civilians per shift operate the
              system, which has over 400 CCTV cameras. They explained that one
              operator could be responsible for viewing up to about 60 monitors, given
              that some of them have screens that can show several camera images
              simultaneously. The operators key in on certain areas known to be crime
              prone, but also scan other areas to detect potential crimes or crimes in
              progress. The operators’ actions are monitored by cameras to help ensure
              compliance with rules governing CCTV use. Officials said that officers
              operate the system 24 hours a day, and the control center also has a tape
              library and facilities for police to review the tapes for evidence.

              Westminster, London

              In Westminster, the borough council and the police department—jointly
              with business and community trustees—manage its CCTV system, which
              became operational in July 2002. An official noted that the purpose of the
              system is to improve the management of public space to enhance public
              safety. For example, the officials said that in addition to controlling crime
              and disorder, they strive to keep the streets clean and ensure free flow of
              traffic. The officials also said their purposes differ between day and night
              in that daytime operations often focus more on the environment on the



              Page 37                                            GAO-03-748 Video Surveillance
Appendix III: Implementation of CCTV
Systems in the United Kingdom




street such as transportation issues, whereas at night they focus more on
crime and disorder.

At the time of our visit, officials said that 17 cameras were in operation,
but that they expected more. An employee of the borough council
managed the center, and the system operators were civilians (contract
staff). Officials noted that the center was a business area partnership and
that the space they were using was provided rent free to the council for
CCTV operations, adding that capital funding for the center came from the
Home Office and local businesses helped to support the operations. The
center had three operator control positions to monitor CCTV cameras and
18 monitors on the wall for viewing and from which operators could pull
images down to their individual monitors to pan, tilt, and zoom to get a
better view.

Officials noted that they perceive their CCTV system as being a “graded
response system” whereby on the basis of what they observe, they can
notify the relevant agency to take action. For example, if an assault is
observed they notify the police, if trash is left on the street they notify the
trash collectors, or if a car were behaving erratically they would call the
traffic department. Officials told us that this type of approach is the
success of CCTV because it helps to focus on what the problem is and
what the solution is. They also said that usually it is not just CCTV that is
the solution, but the intelligence from CCTV that can be used to solve the
problem.

City of Sheffield

The city of Sheffield has been utilizing CCTV, operated by the city council,
since about 1997. Officials said that the UK Home Office funded the capital
costs with grants, while the city council funds system operations and
maintenance. Although this city’s CCTV system is similar in application to
the others we visited, the distinction is that this city has a more “joined up”
concept, whereby all area stakeholders that have CCTV systems (city,
train, mall) can forward camera images to other stakeholders’ systems to
provide a more integrated view of the area. Officials explained that, if
needed (bomb scare or terrorist act), the central control center can take
control of any camera in the integrated system, or the command/control
function can be shifted to one of the other two centers. The police can also
be fed the images real-time from the central control center instead of
viewing images later to assemble evidence. Operators can more easily
follow criminals or criminal activity from one camera/system to the next.
This is important, as these officials noted that the area has two of the UK’s


Page 38                                             GAO-03-748 Video Surveillance
           Appendix III: Implementation of CCTV
           Systems in the United Kingdom




           top 20 terrorist targets (a six-lane bridge that is a vital economic link to the
           north, and one of the UK’s largest shopping malls). If called on a crime,
           however, this city’s cameras can be focused to those areas. At the time of
           our review, officials said that the actual linkage between the three control
           centers (city, train, mall) was to occur in the near future.

           Officials in Sheffield consider the linkage to other CCTV control centers as
           essential to the future success of CCTV. For example, officials said that
           linking of CCTV could be used to determine how many police and
           ambulance units should be deployed or make command/control decisions
           after a terrorist attack, such as finding the best route for emergency
           response vehicles, and re-routing citizen evacuation traffic.




(440156)
           Page 39                                             GAO-03-748 Video Surveillance
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