Many thanks to the International Parking Community (IPC) for inviting me to speak at this event today.

I thought I’d start by giving you some background to my role – apologies if you’ve heard this before.

I was appointed by Home Secretary in 2014 but am independent from government. I oversee compliance with the surveillance camera code of practice. It contains 12 guiding principles which if followed will mean cameras are only ever used proportionately, transparently and effectively.

My remit applies to England and Wales and my role is threefold to:

• encourage compliance with the code
• review the operation of the code
• advise on any amendments to how the code should develop

Relevant authorities (police, police crime commissioners (PCCs), local authorities and non-regular police forces) must pay due regard to the code. It holds relevant authorities to account having a statutory responsibility to do this. For other organisations adoption of the code is voluntary.

The government wants an incremental approach to the regulation of surveillance cameras in England and Wales. To reflect that I don’t have any powers of enforcement. In fact, I don’t believe I require them. Based on what I’ve seen, many organisations who are required to comply are complying or close to compliance. However, it’s a real risk for local authorities and other organisations to ignore the code and doing so would risk reputational damage through appearing unwilling to engage with the public or follow good practice.

So, maintaining public confidence is an incentive for complying with the code.

And there’s no getting away from it: surveillance cameras are everywhere in the UK. A survey by the British Security Industry Association carried out 3 years ago estimated up to 6 million CCTV cameras in the UK. It’s said that in an urban area on a busy day a person could have their image captured by around 300 cameras on 30 different systems.

In the 3 years since the survey we’ve seen body-worn video (BWV) rolled out by most police forces and by other organisations as well as the use of unmanned aerial vehicles – drones – take off and there’s automatic number plate recognition (ANPR) cameras too. I will talk about this in more detail later.

So, that 6 million figure can only have gone up – all these camera types fall within the scope of the code. These figures are indicative of the scale of surveillance, yet give no real indication whether surveillance is necessary nor of compliance with good practice or legislative requirements or meeting any standards at all.

In the 3 years that I’ve been in post one of my mantras has been ‘we must raise standards’, so I thought it might be worth highlighting a few successes from the past few years that we’ve had in that area:

• a self-assessment tool which is easy to use enabling any organisation using surveillance cameras in public places to identify where they are meeting the 12 guiding principles or where they are falling short; it allows them to develop an action plan to show due regard to the code (85% of local authorities have completed the tool)
• a third party certification scheme where such organisations can apply to be assessed for compliance with the code by an independent certification body and if successful use the commissioner’s certification mark for 12 months or 5 years – an outward sign of inward compliance with the code (over 40 organisations are certified against code)
• a passport to compliance – formerly an operational requirement document that puts responsibility for system development in the hands of those that operate them; the passport to compliance will aim to reduce technical jargon to enable procurement experts within organisations to have the ability to properly hold suppliers to account, where non compliance of the code is evident (this is out for testing)
• a list of recommended British, European and international standards published on the commissioner’s website for CCTV operators, installers, maintainers, manufacturers as well as CCTV monitoring companies

Parking on private land: how is this relevant to you

Under the Protection of Freedoms Act 2012, the Secretary of State issued the surveillance camera code of practice with 12 guiding principles on the appropriate and effective use of surveillance camera systems.

The government is fully supportive of the use of overt surveillance cameras in a public place whenever that use is:

• in pursuit of a legitimate aim
• necessary to meet a pressing need
• proportionate
• effective
• compliant with any relevant legal obligations

I am determined to drive up standards in the industry and provide reassurance to communities that public space surveillance is well managed. My goal is that all overt surveillance camera systems are used transparently and that the cameras protecting the public comply with relevant regulation, particularly the code.

Why the parking sector

There is a wide increase in the use of technology in general such as automatic facial recognition, BWV, ANPR, UAVs etc. All these can provide massive benefits to society but at what cost? We only have to look at Operation Champion to see the problems with unchecked use of surveillance (where more than 200 cameras were installed without consultation in a largely Muslim area using funds set aside to tackle terrorism. This sparked outrage and the cameras were removed wasting tax payers money).

Do we run the risk of the UK becoming a bigger surveillance society? A balance needs to be achieved between using technology to improve processes and ensuring the privacy of individuals.

The question is how do we achieve the correct balance?

The use of ANPR has recently become a common theme among many of the big private parking companies. Therefore this topic is particularly relevant today.

ANPR offers parking companies a competent system for issue tickets to vehicles contravening parking conditions on private land. However, is the use of this surveillance mechanism proportionate and how can you ensure that it is being used in compliance with the relevant regulations? The ability to access the DVLA database for registered keeper details means that this data is personal data and therefore is subject to rules under data protection act.

Legitimacy of surveillance

In 2014 the government announced plans to ban the use of CCTV in parking enforcement as it considered the local authorities use of ‘spy cars ‘ was being used as a ‘cash cow’ by councils. It wanted to end the plague of parking fines being sent in the post.

The Deregulation Act 2015 brought this into effect and prohibited the use of devices for parking enforcement, except in specified places, such as outside of schools and bus lanes. This was to curb the abuse of power by the local authority and to avoid devices being used as revenue generators for councils. The use of ANPR for parking on private land can be viewed in the same manner. Is the use of this form of intrusive surveillance legitimate? If yes, then how can we evidence that?

Accuracy of data

ANPR is not without issues though and there are a number of challenges with using this form of surveillance. How do you know that the information provided by the ANPR camera is accurate for example? The fact that a camera has captured a vehicle entering and then leaving an area does not necessarily mean that the vehicle has been parked for that length of time.

For example if a ticket is issued purely on the basis of a camera capturing entry and exit of a vehicle this could be challenged by the driver who could request evidence that the vehicle was actually parked for that length of time.

Another issue around accuracy of information provided by ANPR is a first in last out scenario where a vehicle arrives and parks for a few minutes in the morning and does that same in the evening. If the camera setting is a first in last out one it could issue a ticket on the basis of parking from morning till evening rather then 2 separate half hour periods.

We have to ask ourselves what exactly this information means. What is it telling us? Principle 12 of my code mentions the need to ensure the accuracy of any databases or reference. We need to make sure that data is checked before it is acted upon.

Compliance to the Surveillance Camera code of practice and the IPC code

The use of any form of overt surveillance must adhere to a legitimate and pressing need.

As you will be aware over the last few weeks, there has been a lot of discussion over parking in hospitals. According to the Sun, ‘hospitals raked in a record £125 million in car parking fees over the past year, despite the Health Secretary’s vow to end the tax on sick charges. Shockingly last year’s real figure is thought to be as much as £190 million.’

As parking companies, there must be a way to address this in order to provide transparency to the members of the public. In areas where ANPR is used, it is absolutely essential that the industry gets this right. Completing my self assessment tool could provide a solution and help evidence the fact that these car parks are being operated in compliance with my code.

I have been working with the IPC to incorporate my code into their code of practice and I am grateful to Will and John who have been instrumental in making this happen speedily.

This means that as a member of IPC, in order to comply with the IPC’s code of practice, you should also be able to demonstrate also comply with my code.

You will find this in section 3.5 of the code which states that ‘operators should have regard to the surveillance camera code of practice when using surveillance cameras.’

Under the IPC’s code of practice non compliance with the code could lead to withdrawal of membership as well as the company being reported to DVLA. You will find detailed information about implications of non compliance in part E – schedule 2 of the accredited operator code of practice.

I have put in place a number of tools that will help you to demonstrate compliance to the code. These are my self assessment tool and third party certification.

The self assessment tool is a simple questionnaire that guides you through the 12 principles and helps you to develop an action plan to improve compliance.

Completing this tool will show you how closely you are complying with the code.

The third party certification scheme is for those that are compliant and want to evidence this with a certification mark and a certificate.

More information on these tools can be found on my website.

What’s in it for parking

While the code mentions the importance of relevant authorities showing regard to the code, it goes further to encourage compliance from other sectors that use public space surveillance to adopt the code voluntarily. The parking sector falls into this category of voluntary adopters of the code. The importance of this cannot be over emphasised.

A number of voluntary sectors have adopted the code and already achieved certification. These include some universities, housing associations and most recently Marks & Spencer. None of these organisations have to comply but they have seen the benefits in adopting the code.

So what are the benefits?

Complying with the code provides many benefits, some of which are:

• protecting members of the public
• transparency on how surveillance is used in parking
• improve standards of operating ANPR surveillance within the parking section
• protect the integrity of the industry by ensuring that information used to issue tickets is accurate
• provide consistency across the parking sector
• safe costs on appeals where surveillance cameras show accurate information
• ensure that where ANPR is being used they are compliant with the code of practice which in turn will uplift public confidence in this challenging sector
• adopting the code will help to uplift standards in the parking industry
• potential for reduction in cost through value management and efficiency checks on systems.

Strategy

So, we have had some good successes and you may be thinking: I know he’s consulting on a national strategy (I hope you know I am!), things seem to be improving without one. Well, the surveillance camera sector is massive and is an industry that will continue to grow – there was a £2,120 million turnover in the UK in 2015 on video and CCTV surveillance. That’s virtually enough to buy a Premier League football club!

Think about the surveillance camera industry and all the organisations and people that have a vested interest:

• local authorities
• police forces
• installers, manufactures, consultants and designers
• government and regulators
• members of the public
• all commercial and business sectors

The list goes on – all of these groups often (but not always) are working in isolation, independently of each other.

So, considering the amount invested in the sector and the many groups involved in keeping the public safe – some already working together, there is a need for an overarching, coherent strategy that underpins the use of surveillance cameras bringing together all relevant groups.

As I said, I’ve been in post for almost 3 years now and during that time have been continually impressed by the support, encouragement and engagement across the range of stakeholders. What is clear is the energy for greater co-ordination to improve compliance and raise standards in the world of surveillance cameras. There is certainly an appetite for an over-arching surveillance camera strategy.

This approach was agreed by my advisory council in January and partnership working is at the heart of the strategy – there are 10 work strands all led by an industry expert giving up their time voluntarily to drive this ambitious strategy forward as one coherent plan for the surveillance camera industry.

And it is an ambitious strategy with long-term objectives and delivery plans which extend beyond 2020. My vision for the strategy is quite simple:

The public are assured that surveillance cameras in public places are there to keep and make them feel safe, and that those cameras are deployed and used responsibly as well as transparently in a manner which is proportionate to their legitimate purpose.

And I will do this by providing direction and leadership in the surveillance camera community, to enable system operators to understand best and good practice, and then demonstrate compliance with the principles of the SC code and any associated guidance.

The strategy aims to provide direction and leadership in the surveillance camera community to help system operators to understand best and good practice as well as their legal obligations, such as those contained within the Data Protection Act and the Private Security Industry Act, and then to apply that understanding to demonstrate compliance with the principles of the code and any other associated guidance.

It will provide a blueprint and a delivery plan that will afford significant operational cost benefits, economies of scale, enhanced training opportunities and more focused direction for manufacturers and suppliers. The end result being a more transparent, efficient and effective approach to public space surveillance – benefitting the public who will be safe in the knowledge that surveillance cameras are there to keep them safe and protect them.

This is not the first attempt at a national strategy for surveillance cameras in England and Wales. The 2007 CCTV strategy attempted to do this with regard to CCTV. It was an ambitious, systematic and innovative approach but for a number of reasons much of it didn’t move from recommendations into delivery. Much of today’s strategy owes a lot to the remnants of the 2007 CCTV strategy.

As I said there are 10 work strands to this strategy each with its own objectives – I won’t go through these but you can find them in the draft strategy document on my website.

But briefly, in consultation through their networks the strand leads have identified high level objectives. They each work towards and support achieving the vision and mission.

Each of the strategic objectives will have a supporting delivery plan setting out specific action and outputs which contribute towards achieving the strategic mission. The delivery plans are owned by strand leads.

Consultation

This draft strategy has been 10 months in development – I’ve been working with the strand leads and many others to get it into shape and now we are ready to consult on it.

So, I welcome views from anyone whether they are an expert in the industry or a member of the public – the strategy is designed to benefit them so their input will be invaluable to making sure it meets their needs when we begin work on delivering its objectives in 2017. The consultation is open now and you can submit your views via an online survey on my website – the consultation will remain open until 6 December.

Once we have gather and analysed responses we will feed them back into the strategy to make it even better and publish the final document and delivery plans in 2017.

I am delighted to have the opportunity today to talk to you about lifelong careers, which will play a significant part in this government’s industrial strategy.

The Industrial Strategy Green Paper sets out the government’s proposals for delivering a high-skilled, competitive economy that benefits people throughout the country. Developing people’s skills is one of the 10 pillars of the strategy, and high-quality careers advice will play a key part in realising this ambition.

I see careers advice as the first rung on a ladder of opportunity, a ladder that people will continue to climb throughout their lifetime. However, we know that this ladder does not come to us pre-assembled. It is something that needs to be built, grafted over and shaped to reflect our modern requirements. Government’s job is to be there to hold the ladder and help people to climb up.

I strongly believe that the conditions are right to not only transform the nature of careers guidance, but of technical education and apprenticeships, to give everyone the necessary skills and training to open up opportunities and jobs for their futures.

I am excited to have oversight of all of these areas and the chance to bring a greater coherence to them. In particular, locating in one department responsibility for both young people and adults is an exciting opportunity that can bring about a coherent approach to lifelong careers. It allows us to look across the age range – from primary schools right through to retirement.

I also want to root our approach to careers provision firmly at the heart of the government’s focus on social justice, and our desire to make sure that everyone, regardless of their background, has the opportunity to progress in life.

Our starting point in creating a careers system that works for everyone is to build on what works. I have seen some excellent examples around the country, including the fantastic work here at Westminster Academy. I was also lucky enough to visit Gateshead College last week, where careers learning is weaved into all aspects of students’ learning.

But these are isolated examples and we need to spread good practice more widely. We have begun to do this by adopting a clear, evidence-based approach to what works, and to ensure support is getting to where it is most needed. The Careers & Enterprise Company has been at the forefront of this approach. £90 million is being invested in careers over this Parliament, which includes further funding to the company. And their work is beginning to have an impact. There are now 80 enterprise coordinators and over 1,300 enterprise advisers working with a third of all secondary schools and colleges across the country. Our goal is for 25,000 young people a year to be benefiting from business mentoring by 2020.

As its network of enterprise advisers and coordinators grows, so will its ability to support schools and colleges in delivering real and lasting change in high-quality careers and enterprise strategies, influenced by strong relationships with employers.

For adults too, the National Careers Service continues to offer free and impartial information, advice and guidance on careers, skills and the labour market, with high rates of satisfaction.

So taking this as our starting point, where do I think we need to go next on careers?

1. Improving the prestige of careers

It is clear to me that, although there is good work underway, more needs to be done.

We will consider the perception of careers provision, which for too long has not been seen as a vital part of our education system. For many schools, colleges or employers, high quality careers provision is a priority, but not for all. Tracey Brabin set this out clearly in her powerful speech in Parliament earlier this month, where she highlighted a college that had asked its unqualified receptionist to provide careers guidance to students.

The first step in this journey will be for us to set out our ambitions and plans for careers provision, and, as announced in the Industrial Strategy Green Paper last week, I am delighted to confirm that we will publish a comprehensive careers strategy for all ages later this year.

2. Expand the quantity and quality of careers provision

I believe that there is a need to address the quality and consistency of careers provision across the country, ensuring that we can have confidence that, whatever stage of your life you are at, and wherever you live, the advice and support you are receiving is of the highest calibre. It is for many, but for many, it is not.

But why is that? Why can some schools and colleges provide high-quality advice and support, and others not? What are the drivers for doing so? These are the questions I will be considering. I do not believe that this is just a question of funding, but how a school chooses to spend its funding: schools that provide high-quality careers advice, like Westminster Academy, do not do so because they have a greater share of the pot, but because they see providing high-quality careers advice as being vitally important to the future of their pupils.

Destination measures are emerging as a compelling way of encouraging schools to focus on their role in preparing young people for the next stage of their education, training or employment. The inclusion of destination data in school performance tables is an important step. We will look at ways of making this information as clear and as comparable as possible.

Let me be clear: I want to reach a position where all schools and colleges are offering exceptional careers advice and guidance, through their own comprehensive and tailored strategy.

But if we are to make this a reality, we must have a shared understanding of what good careers provision looks like. The Gatsby Foundation has published its series of benchmarks, which describe the components of excellent careers provision, and I will consider how schools can be encouraged to meet these benchmarks. For now, I encourage all schools to use the excellent Compass tool that allows them to review their progress against the benchmarks.

The Careers & Enterprise Company is a vital part of the support that we provide for schools, boosting the quality of schools’ interactions with employers and the experience of different workplaces they are providing for young people. Indeed, a report published today by Education and Employers highlights the importance of employer engagement in schools in helping young people feel prepared for adult life, and that those from disadvantaged backgrounds recall having fewer employer engagement than their peers. This is something I am keen to address.

3. Meeting the needs of a skills economy

It is clear to me that if we are truly to meet the needs that our economy has for the full range of skilled workers, we need to drive improvements in productivity, and this relies heavily on a stronger and better system of careers advice and guidance.

The challenge facing us is clear: there is a very real gap between what employers are seeking and the skills that people currently have.

To address this challenge and ensure people of all ages are trained in the skills our country needs, we may need to change the way different career paths are viewed. Apprenticeships are delivering fantastic opportunities for many people, and I am incredibly proud of what the government has achieved in this area already. But we need to level the playing field between technical and academic education, so that more and more young people are aware of the benefits of technical education.

We need people of all ages, and those who advise them, to really understand what opportunities are on offer. I want those undertaking apprenticeships or courses in further education to get the same level of information and support to make confident and informed choices when selecting and applying for courses.

We want to ensure that those applying for further education have clear information and support through the process of searching for, choosing and then applying for a particular opportunity. In particular, we want to ensure that they are supported in the same way that higher education applicants are supported through the straightforward and well-understood UCAS system.

In addition, for young people to demonstrate their enterprise and employability skills, The Careers & Enterprise Company are developing a ‘careers passport’ led by Lord Young, which will be a ‘Passport for Life’: a digital record for young people of their enterprise learning and work experience throughout their education to aid transition to employment.

To achieve this we will need to look again at the information that government provides, making sure we are providing resources in the clearest and simplest way, so it is easily accessible to everyone. We will review the linkages between the different organisations and services that are helping to get people into jobs, including the National Careers Service, The Careers & Enterprise Company and the National Apprenticeships Service. I want to encourage co-creation between these organisations that focus on delivering the right outcomes for students, adults and employers. I want greater clarity and coherence, and an increase in grassroots activity, expanding The Careers & Enterprise Company’s fine work in this area already delivered through their enterprise advisor network.

4. Support for the most disadvantaged

We know just how important careers advice and guidance is for those young people who are from more disadvantaged backgrounds or have special educational needs: those who face different challenges or bigger hurdles to overcome when making choices about their future.

We need a careers system that nurtures the aspirations of those who are disadvantaged or have special educational needs, providing them with the additional and targeted support that they need to make those aspirations become a reality. This will mean different things for different people.

And this isn’t just about our young people. This is about tailored support for people most in need, at whatever stage of life.

I will consider what more we can do to help organisations try out different approaches, and find new and innovative ways to make sure we reach those who need our help most. High quality careers advice and support must be for everyone.

5. Job security

In taking action in all of these areas, we mustn’t lose sight of our primary aim and purpose, which is for careers advice and guidance to ultimately lead to meaningful employment. Careers advice is not there as a standalone thing in its own right – it’s the engine room of our plans to drive improved productivity and social justice. The Education and Employers report I mentioned earlier supports this, showing school-mediated employer engagement can:

• reduce the incidence of young people not in education, employment or training by up to 86%
• result in earnings of up to 16.4% more than peers who did not take part in such activity.

So in conclusion, it is clear to me that careers is a vitally important part of my brief, which can make a fundamental contribution to this government’s industrial strategy. To support this, we will publish a strategy that will do the following:

• consider the prestige attached to careers information, advice and guidance
• seek to raise the quality of careers provision for people of all ages
• ensure we are truly addressing the skills needs of our country
• support those who are most disadvantaged and use careers to improve social justice
• focus our efforts on securing the end goal of meaningful skilled employment, ensuring a country that works for everyone

I want to ensure that great careers guidance provides the first rung on the ladder of opportunity, helping everyone to achieve their full potential.

Updated: Change of tense in one paragraph