DFSAA Comment on CCTV for Galway

by Orla Ni Chomhrai Wed Oct 22, 2003 11:28 nichomhrai at eircom dot net

This is Catherine Connolly's submission. She is a Labour Party Councillor in Galway.



Re: Proposed CCTV for Galway City




I am making the following submissions in my capacity as an Alderman on Galway City Council. At the outset I would also like to confirm that as a Councillor I am particularly aware of citizens’ concerns in relation to their safety both in Galway City generally and more specifically in relation to problems arising in housing estates.

Indeed after representations in relation to the housing crisis I would say that the lack of Garda on the ground is the second most common complaint/representation that I receive from residents.

On a general level therefore I would be very interested in looking at any positive proposals which would increase the Garda numbers on the ground and serve to make Galway a safer place for all its citizens.

More specifically then this proposal came to my attention through an advertisement in the Irish Times and subsequently through hearing an interview on this topic which Superintendent O’Cuallain, of Mill Street Garda Station, gave to Radio na Gaeltachta.

On the file which is available for public inspection and which I have inspected the following documents were on file: a written outline of the proposed location of the 18 cameras with technical details together with an accompanying map.

No other documentation of any nature was on the file.

It is not clear to me therefore what the status of this exercise is? Is the Department of Justice, Equality and Law Reform consulting with the public as a matter of courtesy or is it under a statutory obligation to do so.

If the latter, absolutely no attempt has been made to set out what this obligation is, under what legislative provisions/regulations it arises and what conditions if any must be satisfied.

In this regard I note in a letter from the Department to a member of the Public dated the 2nd October, Ref No 4/887/18, a copy of which was given to me- the Department comment and I quote

‘The planning process with Galway City Council commenced on Tuesday 9th September when notices were placed in the national newspapers. This process is due to finish on 21st October 2003. Once this process has been completed, and subject to it, the contractor will be directed to erect poles and camera equipment and connect these to Mill Street Garda Station. It is anticipated that the system comprising 18 cameras will be operational by January 2004’

What is the status of the planning process referred to in this letter to a member of the public but not referred to at all on the file available for public inspection?

What obligations if any is the Department under in relation to taking cognizance of the submissions from the public noting the quote ‘subject to planning process’

What procedural requirements if any such as site notices, inclusion of advertisements on the planning file etc exist?

Who makes the final decision and is it subject to appeal?

On a more general level then I make the following comments/observations:

Statistics on Crime: Data/Research on effect of CCTV cameras on these statistics

The proposal to erect 18 new cameras is made without any attempt to explain/clarify and or justify the necessity for such.

No figures and/or no breakdown for crime in Galway City has been given.

There has been no explanation for the particular locations chosen for the cameras and no attempt has been made to clarify what effect the installation of such cameras will have on crime in Galway City.

Interestingly this failure to provide essential data is all the more significant given the comments that have been made by various Senior Garda Personnel.

For example in the interview on Radio na Gaeltachta cited above the Superintendent confirmed that crimes rates had dropped and/or were coming down in Galway City! Furthermore, Garda Commissioner Pat Byrne in Galway to discuss public order offences in March 2002 is quoted in the local press as follows: ‘the main cause of public order offences in Galway and everywhere else was overconsumption of alcohol’ ..I don’t think it’s fair that the community has to deal with the problems emanating from the licensed trade’ and specifically in relation to CCTV cameras he said ‘people will say it moves crime..yes it does but overall it is extremely helpful to the Garda Siochana’ Incidentally no clarification was given on how it was helpful to the Garda.

In light of such interesting comments and the complete failure to provide analytical data in relation to crimes in Galway City and the effect of CCTV cameras on such crime data, it would in my opinion be most unwise to proceed with this proposal.

Indeed the data that is available from a growing body of research in the United Kingdom including research from the Home Office itself throws serious doubt on the usefulness of Cameras in preventing crime.

This body of research highlights a number of interesting findings including:

the fact that the use of cameras may be more effective as a detection tool than as a deterrent with little evidence that cameras prevent violent crime.

More specifically in relation to crimes against the person including assault, the Criminal Rehabilitation of Offenders (NACRO) in the UK in its report at the end of June 2002 stated that cameras had little effect on such crimes.

Particularly interesting is research commissioned by the Home Office itself which indicates that quite often the use of alternative solutions such as enhanced Street Lighting could be a much cheaper way of cutting illegal activity especially in crime hotspots.

Financial Costs

In addition and particularly worrying no information whatsoever has been given on the costings of the erection, maintenance and operation of the proposed cameras.

However in the letter referred to above prices were quoted which would give me serious cause for concern, namely:

The said letter informs us of the following: the contracted price including associated civil works, for the Galway City CCTV schemes is 450,109 Euro excluding VAT. This price excludes necessary electrical and refurbishment works that have been already been carried out at Mill Street Station to accommodate the system. This work was arranged by the Officer of Public Works and cost approximately 27,700 Euro. This cost however excludes the provision of main power supplies to the cameras. This work will be carried out by the ESB and the cost in relation to same has yet to be determined. In addition we are told the annual cost of maintenance of a CCTV system is approximately 7% of the total capital system. However the cost of monitoring the cameras on an ongoing basis is not mentioned at all.

What is of particular concern here is a) the above figures were not included for public inspection on the planning file b) a total cost has not been provided and c) no attempt made to place this costing in context ie what budget or budgets is it coming from for example Prevention, Detection and/or Prosecution of Crime? More particularly what percentage of which budget is being used for cameras as opposed to other methods such as more Garda being deployed on the ground.

The provision of such basic information is a fundamental prerequisite to enable members of the public make informed submissions on what is necessary to make our society safer.







Nature of Process of Consultation



With regard to this process I have a number of very serious concerns. As stated above this proposal came to my attention through an advertisement in the Irish Times. There is no copy of this advertisement on the planning file nor any copies of other advertisements which I have since learned were in the local press.

As far as I am aware no use was made of the local radio station nor of public meetings to bring this very serious matter to the attention of the public.

In addition it has been brought to my attention that when members of the public contacted the City Council there was enormous confusion as to which Department had the relevant information and what was involved generally in making a submission.

Given the fact that the proposal has such serious implications for a citizens civil liberties and given the fact that 20% of our population are functionally illiterate I find the level of consultation engaged in totally unacceptable.

Moreover of great concern is the fact, as evident from the letter dated the 2nd October and referred to above, that public monies have already been expended in advertising and awarding the Contract for the supply installation and commissioning of the CCTV cameras and also that electrical and refurbishment works including the installation of monitors have already been set up in Mill Street Garda Station!

Given this level of prior decision making what function if any is the consultation process serving?

Existing CCTV Cameras in Galway City

It is not at all clear whether this is an entirely new proposal or whether it is in addition to any existing cameras operated by the Garda Siochana.

As a City Councillor I am certainly aware of two areas in the City where CCTV cameras have been installed by the City Council.

To date I have failed to receive an answer to a motion tabled by me to the City Council a copy of which I enclose herewith.

At the very least I would have thought it essential to have an analysis of how if at all the existing cameras have affected the rate of crime in the City.

Moreover on a personal level as a Councillor I can confirm that the amount of illegal dumping in the areas immediately around the cameras has not been curtailed and indeed the figures quoted by the City Council for the ongoing clean up schedule for one of these areas in particular has exceeded a million Euro. In addition the said cameras have not in any way curtailed the constant illegal burning in the area which continues to pose a serious



threat to the health and safety of the residents of the area. Again I enclose a copy of motion submitted to the City Council re the illegal burning.



Invasion of Privacy and Risk of Misuse of Cameras

There is no data on the planning file in relation to the range of the cameras or the extent to which they will intrude on the privacy of peoples lives.

Moreover absolutely no attempt has been made to clarify who will monitor the cameras or to clarify what will be monitored and/or stored and for how long.

No attempt made to clarify what guiding legislation/regulations if any will govern the Garda in their operation of these cameras.

Again my own experience as a City Councillor has confirmed that that the risk of misuse and/or inappropriate use of such cameras is extremely high.

Indeed it has been brought to my attention that CCTV cameras presumably from the Carn Ard Estate have been used to monitor the movements of a law abiding citizen outside of the Carn Ard Estate. The CCTV footage in question was sent out to this citizen a number of weeks after the housing file had been forwarded under the Freedom of Information Act with the briefest of notes saying that the CCTV footage had been inadvertently left out.

No other explanation or justification was given in this note by the City Council for the use of CCTV footage in this manner.

To intrude on a citizen’s right to privacy with existing cameras in this manner is truly shocking.

To now proceed with the erection of 18 more cameras without an analysis of the effect of the use and/or misuse of existing cameras albeit under the auspices of the City Council is totally unacceptable.



Conclusion

The proposal to erect 18 new cameras in Galway City is premature at this point and should not be proceeded with.

The consultation process to date has been totally inadequate with a failure to provide the most basis of information on crime rates, breakdown of types of crimes and up to date research on effectiveness of CCTV cameras. Without the provision of this most basic of information the citizen cannot be expected to make informed comment on the necessity or otherwise of CCTV cameras.

In addition there has been no attempt to provide alternative solutions such as increased Garda Staffing on the ground and/or more basic solutions such as increased lighting which have been repeatedly demanded by concerned citizens.

Furthermore there has been no analysis of the effectiveness or otherwise of existing cameras nor any mention of the provision of safeguards for the protection of a citizens rights and in particular his/her right to privacy.



The lack of financial costings of the proposal and the failure to place such costings in an appropriate context ie which budget and what percentage of same relative to for example increasing the Garda staffing on the ground is scandalous.

In the circumstances I would certainly ask that the proposal not go ahead and that the information asked for be provided immediately within the context of a meaningful consultation process with the purpose of making Galway City a safer place for all its citizens.

Ald Catherine Connolly

20th October 2003

by Orla Ni Chomhrai Wed Oct 22, 2003 11:50 nichomhrai at eircom dot net

Hi all,

There are plans to put CCTV in many places around the country. These are:

Athlone, Ballyfermot, Bray, Carlow, Castlebar, Clondalkin, Clonmel, Dundalk, Dun Laoighaire, Ennis, Finglas, Galway, Kilkenny, Limerick, Sligo, Tallaght and Waterford.

______

The Department of Justice have not received submissions from any other part of the country other than Galway on this issue, for the areas that they are working on at the moment.

I presume from this that they have advertised certain areas, and my guess is is that these are Bray, Dundalk, Dún Laoghaire, Finglas, and Limerick - or some of these at least as they seem to be working on these first.

You might be interested in the following from a letter I received from the Dept. Of Justice

'The contract for the supply, installation and commissioning of a Garda CCTV system for Bray, Dubdalk, Dún Laoghaire, Finglas, Galway and Limerick - and the associated civil works - was awarded at the end of March 2002 to SKS Communications Limited following a competitive tender competition in accordance with EU and national procurement rules.

Work is currently ongoing in each of these locations and it is intended that the installation of cameras will commence on completion of the planning process with the relevant local authorities. '

They went ahead with some of the work before consulting people in Galway, and so possibly in other parts.

There are two pieces here from the Irish Council for Civil Liberties on CCTV plans

http://www.iccl.ie/criminalj\order\cctv_02.html
http://www.iccl.ie\criminalj\policing\cctv00.html


For information on CCTV, lack of effectiveness and invasion of Privacy here is are a few of the sources I used in the submission I wrote up:

1. CRIME AND CRIMINAL JUSTICE RESEARCH FINDINGS No 30 , July 1999, THE SCOTTISH OFFICE CENTRAL RESEARCH UNIT http://www.scotcrim.u-net.com/researchc2.htm

2. Crime Prevention effects of closed circuit television: a systematic review, Home Office Research, Development and Statistics Directorate, August 2002 by Welsh and Farrington
http://www.homeoffice.gov.uk/rds/pdfs2/hors252.pdf

3. TO CCTV OR NOT TO CCTV? A REVIEW OF CURRENT RESEARCH INTO THE EFFECTIVENESS OF CCTV SYSTEMS IN REDUCING CRIME
http://www.nacro.org.uk/templates/publications/briefingItem.cfm/2002062800-csps.htm

4. David H. Flaherty, Information and Privacy Commissioner for British Columbia, March 31, 1998. http://www.oipcbc.org/investigations/reports/invrpt12.html#1e


5. Privacy Commissioner's finding on video surveillance by RCMP in Kelowna, October 4, 2001. The Privacy Commissioner of Canada, George Radwanski, letter to David Loukidelis, Information and Privacy Commissioner of British Columbia, following an investigation of video surveillance activities by the Royal Canadian Mounted Police (RCMP) in Kelowna, B.C.
http://www.privcom.gc.ca/cf-dc/02_05_b_011004_e.asp

See also http://www.oipc.bc.ca/new/rlsgen/videosuveillance-Kelowna1.pdf

6. Justice Gérard La Forest, former Justice of the Supreme Court of Canada, April 2002 http://www.privcom.gc.ca/media/nr-c/opinion_020410_e.asp

7. Chief's Friend Accused of Extortion
http://www.washingtonpost.com/wp-srv/local/longterm/library/dc/dcpolice/stories/stowe25.htm

8. Cops tap database to harass, intimidate
http://www.freep.com/news/mich/lein31_20010731.htm

9. 'Surveillance, Order and Social Control' 1997 Clive Norris, Department of Social Policy, University of Hull.
http://archive.aclu.org/issues/privacy/CCTV_Norris.pdf

10. CHAMBER JUDGMENT IN THE CASE OF PECK v. THE UNITED KINGDOM
http://www.echr.coe.int/Eng/Press/2003/jan/Peckjudeng.htm