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Encouraging the use of CCTV in taxi and private hire vehicles

Instead of making CCTV compulsory, why don’t we help professional drivers to fully understand the benefit of a good security system?

CCTV

I have been thinking a lot about CCTV recently, especially in light of the Department for Transport’s Taxi Standards, 2020, and the requirement that all licensing authorities should:

‘consult to identify if there are local circumstances which indicate that the installation of CCTV in vehicles would have either a positive or an adverse net effect on the safety of taxi and private hire vehicle users, including children or vulnerable adults, and taking into account potential privacy issues’.*

As somebody who ran a Community Safety Partnership project on the installation and use of CCTV by taxi and private hire drivers, and as somebody who speaks regularly with lots of new and existing drivers about the use of CCTV, I feel somewhat qualified to speak about some of the issues concerning the use of CCTV in licensed vehicles.

Protected Communities, Driver Well-Being

As a licensed driver myself (non-practising) there is no question I would install CCTV in my vehicle if and when I do begin to venture out. Why? Well, as a licensing officer of 15 years experience, I saw first-hand the benefit of CCTV in clearing up all sorts of licensing related incidents (not just taxi and private hire). I saw plenty of occasions when CCTV would have been of benefit to either customer or business owner (or both), had it been installed. Unfortunately, I saw quite a bit more of the latter than the former.

This is isn’t because of the number of incidents. Thankfully, that number was relatively low. It is because very few taxi and private hire business owners, particularly those who have been driving for a long time, choose to install a camera. Given the available evidence showing how CCTV can improve safety for drivers and passengers, this doesn’t seem logical. In fact, when a driver comes on one of our courses and talks about having CCTV they are always positive about its effect on safety. I can’t think of a single time a driver has turned up and said it was a waste of time.

image shows a drawing of a typical dashcam type CCTV camera.

Who is in control?

I think this discrepancy is important for authorities and drivers alike.  If we can understand and overcome the reasons behind this trend, then we can encourage voluntary take-up of CCTV instead of insisting upon it, and that, I believe, would be better for all concerned.

Firstly, and very importantly, I believe it would be better because data protection rules require all of us, including local authorities, to investigate less intrusive means of dealing with issue that may be solved through the installation of CCTV. I suggest that thoroughly exploring the voluntary take-up of CCTV is a less intrusive way of solving the issue.

Secondly, if authorities decide to mandate CCTV, then quite aside from the justification, there are all the other considerations: cost, officer time, committee time, consultations, reports, procurement of suppliers. And this is before we even get to on-going management of the system. Imposing CCTV is expensive. Justification is, quite rightly, lengthy and complex~. Wouldn’t it be much better to overcome the barriers to voluntary take up instead?

Lastly, from a business owner point of view, the issue is perhaps more straight-forward. Who do you want to be in control of the CCTV system in your vehicle? You? Or the authority? I know which I would prefer. The higher the voluntary take-up, the lower the chance of mandatory imposition.

Three main issues

What are the barriers and how do we overcome them? How do we encourage?

How do we address the concerns of the trade?

First of all, we have to know what they are. Here is what I have learned from talking with thousands of drivers from across the country:

Privacy

Licence holders are concerned about, and protective of, their privacy. Quite right. So am I.  Lack of clear information about the use of CCTV can lead to a situation where drivers form the wrong impressions about who really has control over the system.

Once you install a camera, can the authority dial-in and download footage on a whim? Can they swoop in at the dead of night, no reason given, and demand everything is handed over for forensic level investigation?

Well, no, is the simple answer to these questions, but a mistrust of the system persists. It doesn’t help that much of the information given online about the use of CCTV in vehicles is confused or difficult to follow. Professional drivers and authorities should be partners in reducing crime and improving community safety. Clearly explaining the rights and restrictions of all sides would go a long way to addressing legitimate concerns over privacy.

Image shows a privacy policy on a clipboard with a phone and cup of coffee beside.

Cost

Running a taxi or private hire business means having the right equipment. Clearly, a vehicle of some type is essential. But what about additional equipment that seperates the private car owner from a professional driver? Do drivers think about their vehicles as, first and foremost, a place of business? Or is it a ‘private car’ that also happens to be used as a taxi? (I know the legal definition, I’m talking more about the reality of how things are sometimes seen).

Additional equipment carries a cost, but what is the cost of a mid-range CCTV system compared to the price of a vehicle less than 5 years old, or Euro 6, or whatever it is that the authority requires in their licensing conditions?

What is the cost of CCTV in comparison to potential reductions in the price of insurance? Or the health and well-being of a community?

For authorities, the question should be: are our drivers thinking about things in these terms? Are we?

Is there more that authorities can do to help drivers consider these issues?

Some insurers are offering significant discounts for drivers who install CCTV. Are drivers calculating the savings against initial outlay? There is a problem, of course, that the insurer may be insisting on a particular brand or type that does not meet local licensing conditions. Who is the data controller in these circumstances and do licence holders realise what this means? Can authorities do more to work in a connected way? Some system requirements from authorities are so complex they make Shakespeare seem easy in comparison. Is there a real need for this?

Finally, for a business owner, what is the cost of a disputed insurance claim? An allegation? Of having a licence suspended or revoked?

CCTV could prevent any of these things from happening, keeping a business on the road.

Panic!

This is another linked to understanding of rights and restrictions. You cannot record audio ever, no matter what! (said someone who hadn’t quite understood the law).

Of course, there is a place (and, in many cases, a need) for panic buttons and on/off switches and warning lights, but do drivers fully understand the reasons for why they may need them? Just as importantly, do they understand that, as business owners, it is down to them to make these decisions on justification? After all, these are private businesses. They are just as capable (fit and proper, safe and suitable?) as any other pub, restaurant, shop or late night takeaway of deciding if there is a pressing need to run a system, and of doing so legally and effectively, aren’t they? And if they aren’t, if they pose some sort of danger or risk by having control over personal and sensitive data, why are we licensing them in the first place? We can’t have it both ways.

Now extend this responsibility to cover all of the data protection rules. Data protection is incredibly confusing even for experts. How much are we helping drivers to understand what they should and should not be doing? It really isn’t enough to say ‘sign up to the ICO as a data controller’. What about DPIA’s, LIA’s, SAR’s?

The maximum fines for getting things wrong are huge. Criminal offences can be committed. In the end, it is often less stressful for a driver to take the easier option of no CCTV.

Less Intrusive

These are my top three reasons why drivers don’t use CCTV already – general suspicion, a misunderstanding over costs, and a fear of getting it wrong. All three can be easily solved with a bit of training, advice and direction.

In the long run not only will this be better for the health and welfare of licence holders and communities, it will also be less costly and risky for local authorities. Crucially, it would satisfy the ICO’s requirement for authorities to explore less intrusive options ahead of any blanket requirement forced upon the trade.

* https://www.gov.uk/government/publications/statutory-taxi-and-private-hire-vehicle-standards

~https://www.local.gov.uk/publications/developing-approach-mandatory-cctv-taxis-and-phvs

Title image for the course showing some icons such as cctv camera, magnifying glass, report and safety shield

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