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.

(440156)

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