    Video Surveillance: Information on Law Enforcement's Use of
    Closed-Circuit Television to Monitor Selected Federal Property in
    Washington, D.C. (27-JUN-03, GAO-03-748).

    Law enforcement use of closed-circuit television (CCTV) as a tool
    to fight crime and terrorism has become more prevalent over time.
    Civil liberties advocates have raised privacy concerns about its
    use. This report describes (1) the Metropolitan Police
    Department's and the United States Park Police's implementation
    of CCTV to monitor public spaces in the Washington, D.C.,
    metropolitan area such as the National Mall and (2) the
    management controls they established to address privacy concerns.
    GAO also identified experiences of selected CCTV users that
    provide insights to help ensure the proper CCTV use.
    -------------------------Indexing Terms-------------------------
    REPORTNUM:   GAO-03-748
        ACCNO:   A07410
      TITLE:     Video Surveillance: Information on Law Enforcement's Use
    of Closed-Circuit Television to Monitor Selected Federal Property
    in Washington, D.C.
         DATE:   06/27/2003
      SUBJECT:   Closed circuit television
    	     Electronic surveillance
    	     Internal controls
    	     Law enforcement
    	     Law enforcement agencies
    	     Right of privacy
    	     Crime prevention
    	     Civil liberties
    	     Baltimore (MD)
    	     Columbia (SC)
    	     Tampa (FL)
    	     Virginia Beach (VA)

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    GAO-03-748

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

    United States General Accounting Office

    GAO

    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

    The Metropolitan Police Department of the District of Columbia*s CCTV
    system was implemented, among other things, to facilitate crowd management
    during large demonstrations; however, officials indicated that the system
    could also be used to help combat terrorism. The system is used on an as-
    needed basis for such things as crowd control and when the national
    terrorism threat level is set to high alert (code orange). The
    Metropolitan Police Department obtained public comments on its
    implementation of CCTV. In contrast, the United States Park Police uses
    CCTV, among other purposes, primarily to combat terrorism and operates its

    CCTV system on a continuous basis. The United States Park Police has not
    obtained public input on its implementation of CCTV, but it is considering
    providing the public an opportunity to provide input.

    The Metropolitan Police developed regulations and the United States Park
    Police developed draft policies for operating their CCTV systems. Both
    include management controls that address the protection of privacy and the
    proper use of CCTV such as the need for supervision to protect against
    improper use and the establishment of procedures to control access to CCTV
    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 Law enforcement use of closedcircuit television (CCTV)
    as a tool to fight crime and terrorism has become more prevalent over
    time.

    Civil liberties advocates have raised privacy concerns about its use. This
    report describes (1) the Metropolitan Police Department*s and the United
    States Park Police*s implementation of CCTV to

    monitor public spaces in the Washington, D. C., metropolitan area such as
    the National Mall and

    (2) the management controls they established to address privacy concerns.
    GAO also identified experiences of selected CCTV users that provide
    insights to help ensure the proper CCTV use.

    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.
    Highlights of GAO- 03- 748, a 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.

    Page i GAO- 03- 748 Video Surveillance 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 Contents

    Page ii 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

    This is a work of the U. S. Government and is not subject to copyright
    protection in the United States. It may be reproduced and distributed in
    its entirety without further permission from GAO. It may contain
    copyrighted graphics, images or other materials. Permission from the
    copyright holder may be necessary should you wish to reproduce copyrighted
    materials separately from GAO*s product.

    Page 1 GAO- 03- 748 Video Surveillance 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 spaces 1 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. United States General
    Accounting Office Washington, DC 20548

    Page 2 GAO- 03- 748 Video Surveillance Association 2 (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 Union 3 (ACLU),
    the Electronic Privacy Information Center 4 (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 3 GAO- 03- 748 Video Surveillance International Association of Chiefs
    of Police 5 (IACP), and the Security Industry Association 6 (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

    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. Results in Brief

    Page 4 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 5 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
    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. Background

    Page 6 GAO- 03- 748 Video Surveillance Figure 1: Key Aspects of a CCTV
    System 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 cheekbones, 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.

    Police officer Monitor Public space

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

    CCTV Camera

    Page 7 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 RAND
    8 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 8 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 (10 th 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 9 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 10 GAO- 03- 748 Video Surveillance MPDC and the United States Park
    Police have implemented their CCTV systems with varying purposes and
    guiding protocols. The purposes of

    MPDC*s and the United States Park Police*s CCTV systems differ; however,
    both entities have installed cameras in locations that are at high risk
    for terrorist attacks. When the Department of Homeland Security*s 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. MPDC and United

    States Park Police Implementation of CCTV

    Page 11 GAO- 03- 748 Video Surveillance Figure 2: CCTV Cameras Monitoring
    Public Spaces

    Page 13 GAO- 03- 748 Video Surveillance MPDC*s CCTV system is generally
    intended to help manage public 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 Center 15 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. MPDC Operates CCTV on

    a Limited Basis

    Page 14 GAO- 03- 748 Video Surveillance Figure 3: A CCTV Control Room

    MPDC drafted regulations and an implementing general order on the use of
    CCTV in June 2002. These documents were made available to the ABA 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). MPDC Has Regulations

    That Govern Its Use of CCTV

    Page 15 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.

    The United States Park Police is installing CCTV cameras to combat
    terrorism and to further law enforcement and public safety objectives.
    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.* United States Park Police

    Operating CCTV on a Continuous Basis

    Page 16 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.

    The United States Park Police*s use of CCTV is not specifically governed
    by any federal law or regulation. While there may be limitations
    protecting 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). United States Park
    Police

    Is Developing a Policy to Guide Its Use of CCTV

    Page 17 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
    Park Police officials said that they were drafting a policy to address
    issues raised by civil liberties advocates. Both the regulations and the
    draft policy

    have incorporated management controls to address issues regarding
    individual privacy and the proper use of CCTV. Regarding the issue of CCTV
    effectiveness, MPDC and the United States Park Police both maintained that
    CCTV is an effective law enforcement tool and that they plan to measure
    the effectiveness of their CCTV systems. However, both

    entities are of the opinion that measuring CCTV effectiveness may be
    difficult.

    MPDC*s regulations and the United States Park Police*s draft policy
    address the protection of individual privacy in the following ways: MPDC*s
    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. MPDC and United

    States Park Police Officials Said that Regulations and a Draft Policy
    Address Concerns

    MPDC and United States Park Police CCTV Privacy Policies

    Page 18 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 19 GAO- 03- 748 Video Surveillance MPDC and United States Park Police
    officials have in place or are putting in place, respectively, management
    controls for operating their CCTV systems and handling CCTV images.
    Specifically, MPDC*s regulations and the United States Park Police*s draft
    policy address the need for

    appropriate supervision to protect against inappropriate use of their
    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. MPDC and the United

    States Park Police CCTV Management Controls Address Proper Use of CCTV
    Systems

    Page 20 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 21 GAO- 03- 748 Video Surveillance A D. C. official said that the
    effectiveness of MPDC*s CCTV system is difficult to measure because of its
    limited use of the cameras. Further, 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
    cameras specifically to detect crime. The regulations state that the
    general purpose of the cameras is to help manage public resources during
    major

    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.

    MPDC made its regulations available for public comment and held hearings
    regarding the operation of its CCTV system. At hearings, MPDC received
    positive and constructive feedback regarding its CCTV MPDC and the United

    States Park Police Perceive Measuring the Effectiveness of CCTV to be
    Difficult, but Plan to Develop Measures

    Public Feedback on MPDC*s Regulations

    Page 22 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 that they considered beneficial to help ensure proper and
    effective use of CCTV systems. Because of their extensive use of CCTV to
    deter, detect, and investigate crime, the experiences from UK officials
    offered a greater number of best practices than the selected U. S. cities,
    though models from 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 grappled with how to measure the effectiveness of
    their CCTV systems.

    UK officials said that gaining acceptance of their CCTV systems was based
    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 Experiences of Other CCTV
    Users in the

    United States and UK Reveal Best Practices for Other Interested Locations

    Public Notice Helps to Address Privacy Concerns

    Page 23 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. The UK
    government saw a need to establish controls over the use of CCTV systems
    in order to maintain public confidence. UK officials generally 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 Having Standards
    Helps to

    Alleviate Objections to the Use of CCTV

    Page 24 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 Commissioner 22 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 25 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 26 GAO- 03- 748 Video Surveillance Figure 6: Police Officer
    Monitoring a CCTV System

    To help ensure that CCTV systems are used effectively, some CCTV users in
    the UK indicated that it is important to have a plan prior to the
    implementation of the CCTV system that should include clear, realistic,
    and measurable goals for the CCTV system, as well as how CCTV might
    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 Clear Goals
    and Purpose

    Help Ensure Appropriate Use and Alleviate Concerns Raised

    Page 27 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.

    UK officials said that they preferred a well- trained and professional
    staff to operate their CCTV system. According to one UK official, CCTV
    systems 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. Training and Audits
    May

    Help to Ensure Proper Use of CCTV

    Page 28 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

    CCTV users in the United States and the UK have indicated that an
    important consideration in handling CCTV images is providing controls to
    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
    Procedures for Handling

    Data Helps to Ensure Data Are Used Appropriately

    Page 29 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.

    Researchers and others stress the importance of measuring effectiveness of
    CCTV systems in order to justify costs and the potential impact on
    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
    governmentoperated 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 Measuring Effectiveness of

    CCTV Perceived to be Difficult, but Desirable

    Page 30 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

    as part of their overall strategies to address crime and terrorism. While
    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 Concluding

    Observations

    Page 31 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
    report from MPDC and the Department of the Interior. Officials from both
    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
    Agency Comments

    and Our Evaluation

    Page 32 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

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

    Appendix I: Scope and Methodology Page 34 GAO- 03- 748 Video Surveillance
    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 International 2 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.

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

    Systems in Selected U. S. Cities

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

    Appendix III: Implementation of CCTV Systems in the United Kingdom

    Page 37 GAO- 03- 748 Video Surveillance 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 Appendix III: Implementation of CCTV

    Systems in the United Kingdom

    Appendix III: Implementation of CCTV Systems in the United Kingdom

    Page 38 GAO- 03- 748 Video Surveillance 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

    Appendix III: Implementation of CCTV Systems in the United Kingdom

    Page 39 GAO- 03- 748 Video Surveillance 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.

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