Many of our major supermarkets – including the likes of Morrisons, Marks & Spencer, Waitrose, the Co-op and Sainsbury’s – have all promised that CCTV images captured in slaughterhouses/abattoirs will be independently monitored (a procedure called for, in fact, by animal rights-focused group Animal Aid).
Those promises follow on from a campaign orchestrated only last year by that organisation and involving the undercover filming of alleged brutality in slaughterhouses.
Tim Smith, chief executive of the Food Standards Agency (FSA) – an organisation which regulates abattoirs in the UK – recently stated that the images filmed by Animal Aid were “sickening”. While Smith did not condone the methods that campaigners may have used to capture what happens within – they had allegedly trespassed on abattoir premises and planted small, fly-on-the wall cameras – he did acknowledge that Animal Aid had triggered a rethink on abattoirs.
From my own perspective, I’m certainly in no way against the use of technology to ensure that the welfare of every creature on the planet is treated appropriately, but are we forgetting about the humans in this scenario?
Correct management of the solution
The way in which the Animal Aid footage showed those animals being inhumanely slaughtered was terrible, and I for one knew that something needed to be done and quickly.
However, like many incidents that have been identified throughout different sectors, I look at this proposed fast resolution – ie the installation of CCTV – and suggest that this could just be a ‘quick fix’ in an attempt to render a solution for what is undoubtedly a larger problem.
Whatever the proposed solution, it must be managed both correctly and legally.
Let’s assume that CCTV is the answer (an approach I can see working, incidentally). Who is carrying out independent assessments on the installed systems to ensure that they are compliant with Data Protection legislation regarding the image (data) management?
From CameraWatch’s vast and varied experience of assessing CCTV systems throughout the UK, far too many have not even been assessed for Data Protection compliance in accordance with the CCTV Code of Practice issued by the Information Commissioner’s Office.
In truth, most surveillance systems do not meet the legal requirements outlined in that Code and some – a good number, unfortunately – even fail purely on the basis that their end users think they record for 31 days when they actually record for as little as there. Where is the public confidence there. I ask you?
A basic question arises… When the decision was taken to install these systems, did the data controllers – do end users even know that they need one, and who they are? – ensure that they made it fully legal with the compliance requirements of Data Protection?
Did they take steps to protect the employees who do the job properly with the aim of preserving their own Human Rights?
For instance – and here’s a very simple example which is so easy to get right – do you know that at least one of ‘The Big Five’ supermarkets hasn’t even suitably registered with the Information Commissioner’s Office for the use of CCTV?
Knee-jerk reaction leads to bad reputation
Unfortunately, it’s a knee-jerk reaction like this that gives CCTV a bad reputation.
Today, there are so many examples of organisations rushing to install CCTV as the all-encompassing magic wand to all their woes… like managers using CCTV to spot smokers within the school grounds or installing surveillance systems in school toilets because soap is being nicked, or fishing vessel owners making use of CCTV to manage stock quotas, etc.
As I’ve said numerous times, CameraWatch is all for the use of CCTV as a device for many applications outwith than for just spotting crime, but it must be done correctly and legally.
Going back to my central point, are we really ensuring the rights of every creature in these abattoirs? I’m afraid that I cannot give an affirmative answer on that as it certainly would appear that the deployment of CCTV in slaughterhouses has been initiated in breach of the Data Protection Act.
It also means that by installing surveillance regimes not in accordance with the law, any charges brought against a person through use of the CCTV images can be challenged before a Court of Law during proceedings.
This then opens the opportunity for anyone who is captured on these CCTV systems to take legal action against the data controller of the systems in question. The illegal capture of data (the images from the system are people’s personal data) is a major CameraWatch concern in this situation.
Protection and improvement of standards
Of course it’s not all doom and gloom because these matters can be resolved to ensure that surveillance meets the necessary requirements of the law simply by undertaking a full assessment of the current systems (in accordance with CameraWatch standards and the Information Commissioner’s Office CCTV Code of Practice) and applying the changes required to ensure that the data (image) capture is lawful and, just as importantly, that the system actually protects and improves the standards as it has set out to do.
Waitrose stated that there had been “absolutely no suggestion of poor animal welfare” at any of its dozen suppliers, and that ‘signing up’ to meet Animal Aid’s requests was not difficult because it had “nearly full coverage anyway” and only needed to install “a couple of extra CCTV cameras at a couple of processors”.
May I ask a simple question here? If Waitrose has no reason to install these extra cameras then why is it doing so?
One of the first requirements of the Information Commissioner’s CCTV Code of Practice is to justify the use of CCTV and decide the actual reasons for that CCTV system.
If Waitrose had assessed the situation and agreed that there isn’t any issue which requires the application of CCTV cameras then legally the company should not install them. Do I really need to ask the questio, then? Why has more CCTV been installed?
The Unison Trade Union, which provides a representation of meat inspectors and vets in slaughterhouses, said it would wait to see if the introduction of CCTV had a positive or negative impact on workers.
Unison stated that it did not think CCTV’s use would tackle the main problems it saw in abattoirs, which are “too fast a line-speed, which makes thorough inspections impossible”, too few inspections and dirty carcasses making it through the production line.
Earlier this month, we saw employees protest in public in the city centre against Derry City Council due to the perceived incorrect use of CCTV systems. This protest was based on, dare I say it, alleged misuse of the public space CCTV system on which the whole public depends.
Are we being too hopeful that the same situation does not happen in a city near you in the near future? I fear not.
Response from the Food Standards Agency
Following direct CameraWatch communications with the Food Standards Agency, its response to this whole issue was as follows:
“The FSA is an enforcement body with veterinary and inspection presence in abattoirs as required by legislation. Under current legislation the FSA cannot enforce abattoir operators to install CCTV, although it is actively encouraging them to do so for animal welfare purposes. Any decision to install CCTV will be taken by the abattoir operator. As mandatory installation will require a change of legislation, there is currently no need for the FSA to consider any compliance issues in respect of CCTV”
Does this by any chance seem familiar with local authorities Licensing Boards’ instructions to licencees with regards to selling alcohol? May I respectfully suggest that there is a major problem ready to explode?
Clearly, the FSA understands the need to improve the ability to check that the slaughter of animals is being conducted humanely. It appears the organisation also understands that the practicalities of enforcing the use of CCTV in abattoirs cannot be done just by the installation of a number of cameras.
It would seem that ‘The Big Five’ supermarket chains have taken on board the concerns of the wider public with regard to Animal Rights and quite correctly so, but have they ignored or perhaps not understood the legal implications of Human Rights from which current Data Protection legislation is derived?
Out of sight, out of mind… at least for the time being
The fact remains that the public relations of today’s buyers and the press ensure that the job gets done regardless of the issues that may spawn from the original issue: as long as it’s not being thought of or spoken of then it can be remedied later.
From a CameraWatch viewpoint, we believe there’s a need to change and develop systems that ensure these processes are undertaken appropriately.
We also need to know and see that the application of CCTV surveillance and monitoring is undertaken in the same lawful manner.
How can you justify the use of an illegal system to monitor illegal activities? It’s a question I often ask at presentations.
If you invest money and time in ensuring that you implement a compliant CCTV system, you must also ensure that it meets the relevant legal requirements.
We would welcome the opportunity of working with all of the major supermarkets in order to ensure that whatever CCTV solution is proposed it will actually do what it’s supposed to do in a legal manner and will not bear the threat of non-compliance and illegal operation.
As ever, CameraWatch continues to support the use of CCTV systems as long as they meet their stated legal requirements under the Terms and Conditions of the Data Protection Act.
Paul Mackie is the compliance director at CameraWatch
Mackie boasts a 30-plus year background in IT working with both international blue chip companies and also national Government, during which time he dealt with compliance and legalisation of industry software
Further information on CameraWatch
CameraWatch is a group aimed at promoting awareness and compliance of the Data Protection Act for camera surveillance in both the private and public sectors. The organisation has the support of the industry regulator, namely the Information Commissioner’s Office.
A need has been identified for a central information point for the industry. CameraWatch is an independent, not-for-profit, self-funding advisory body* that supports the understanding of CCTV and compliance with current policy and legislation, removing risks relating to data protection and other legal non-compliance.
CameraWatch represents the interests of members through liaison with legislative, prosecution and Government organisations throughout the UK and the EU.
In consultation with the Information Commissioner’s Office, the organisation facilitates the implementation of the ICO’s CCTV Code of Practice and builds up and disseminates Best Practice guidelines designed to support compliance in the use of CCTV systems, their operation and procedures and (where appropriate) prosecutions using CCTV evidence.
CameraWatch offers support tailored to meet the needs of specific organisations, as well as the general public. To these ends, the organisation undertakes R&D project work and market research.
Promotion of data-sharing forums
CameraWatch also promotes regular meetings/seminars and data-sharing forums with the police and law enforcement agencies, the ICO and other security working groups, suppliers/manufacturers and installers and CCTV applications users from all affected sectors (such as retail, transport, finance, insurance, property management and construction, the licensed trade, industry consultants, the security industry, the legal profession, local authorities and other related bodies).
CameraWatch’s activities are currently funded by industry sponsorship and membership fees. The organisation celebrated its Fifth Anniversary in March this year.
CameraWatch’s CEO Gordon Ferrie is a recognised expert in banking security. He was the director of the Fraud Squad and deputy head of CID operations at Strathclyde Police, and is a former worldwide head of security for the Royal Bank of Scotland Group.
Currently a director of ComSec, Ferrie is the CEO of CameraWatch in a volunteer capacity.
Along with Ferrie and Paul Mackie, five other directors make up the Board of CameraWatch.
*CameraWatch is a company limited by guarantee and recognised by HMRC as a not-for-profit organisation
Access more detail on the CameraWatch website (a dedicated link is provided at the foot of this page)
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