The Biometrics and Surveillance Camera Commissioner has published responses to two consultations on the use of CCTV in taxis and private-hire vehicles.
The first consultation (Department for Transport: Taxi and private hire vehicle licensing: protecting users) ran from 12 February to 22 April 2019. It is now concluded.
In the response, the Commissioner (then Tony Porter) warned that requiring the installation of CCTV in taxis as a blanket licensing condition may be disproportionate and the recording of audio required even greater justification.
Furthermore, he would expect to see widespread consultation, a data protection impact assessment, clear procedures for accessing footage, cybersecurity where necessary and the establishment of a full operational requirement.
Link to consultation: https://www.gov.uk/government/consultations/taxi-and-private-hire-vehicle-licensing-protecting-users
Link to Commissioner's response: https://www.gov.uk/government/publications/surveillance-camera-commissoner-response-to-the-department-for-transport-consultation-on-taxis/response-to-the-department-for-transport-consultation-on-taxi-and-private-hire-vehicle-licensing-accessible
The second consultation (Transport for London: In-vehicle closed circuit television in taxis and private hire vehicles) ran from 9 February to 22 March 2021.
In the response, the Commissioner (newly appointed Fraser Sampson) reiterated that a local authority is required to have regard for the Surveillance Camera Code of Practice (SC Code) and would be expected to be able to demonstrate adherence to the code at all stages of implementing CCTV in taxis. https://www.gov.uk/government/publications/surveillance-camera-code-of-practice
He also repeated the warning about imposing CCTV as a blanket licensing condition and the recording of audio.
He said where possible less intrusive solutions to problems should be considered ahead of CCTV while acknowledging that all situations are unique and rest on the discretion of the decision-maker.
He said owners of CCTV systems should be able to satisfy themselves that systems do not create unacceptable bias which requires clear evidence from the manufacturer and a commitment to keep this under review.
The public have a right to assume that public bodies have ensured that the use of surveillance systems is justified and kept under regular review, he said.
Link to consultation: https://consultations.tfl.gov.uk/tph/in-vehicle-cctv/