Licensed vehicle CCTV consultation 2023

We consulted on whether it should be mandatory to install CCTV inside taxis and private hire vehicles in Peterborough.

The Department for Transport (DfT) published statutory guidance in July 2020 which provides a strong focus to protect all passengers and users of taxis and private hire services.

Our consultation started on 6 November 2023 and ended on 2 February 2024.

Why we consulted

By consulting, we can consider if local circumstances exist that indicate CCTV installation in licensed vehicles would have a positive or negative effect on the safety of:

• Licensed vehicles and drivers
• Passengers (some of whom will be vulnerable)

Some positive effects would be:

• Deterring and preventing the occurrence of crime
• Reducing the fear of crime
• Assisting the council and police in investigating incidents and allegations of crime
• Assisting insurance companies in investigating incidents of crime

Some negative effects could be:

• Privacy concerns for licensed drivers and passengers
• Cost implications for the proprietors (owners) of licensed vehicles
• Possible reduction in licensed vehicles
• Possible increase in 'out of area' licensed vehicles (licensed by a different authority and not subject to CCTV requirements)

The aim of taxi and private hire legislation is to ensure the public have reasonable access to the services. There is a primary focus on public safety, safeguarding and wellbeing. 

We appreciate your views to help inform us whether we should make CCTV installation mandatory in taxis and private hire vehicles in Peterborough.

Our Licensing Committee will fully consider the survey results and all other consultation responses before making their recommendation to Full Council.

If CCTV became mandatory

• We would carry out a full Data Protection Impact Assessment (DPIA)
  
  
• We would undertake an engagement activity to identify CCTV suppliers and installers, with consideration to specification and cost. The proposed technical specifications for CCTV systems align with those adopted by other licensing authorities. We would require suppliers and installers to ensure that the CCTV system would not negatively impact on the operation of the vehicle. You can view the draft specification below.
  
  
• The costs to purchase, install and annually maintain the CCTV equipment would fall to the vehicle proprietor. Any CCTV systems already installed in licensed vehicles would need to meet our specification.
  
  
• We would take a phased-in approach to give proprietors time to comply once the policy is live. No sooner than 12 months and no later than 18 months.
  
  
• The policy would be amended and conditions would be attached to driver and vehicle licenses regarding installation and use of the equipment
  
  
• We would require licensed drivers to ensure that CCTV is always operational when 'on duty' in their role of conveying paying passengers in a licensed vehicle. This includes waiting on a rank, when going to collect a fare and returning from a drop off, even though no passengers are in the vehicle. An exemption may be applied for speciality / executive vehicles.
  
  
• As the policy will require all licensed vehicles to have CCTV in operation when 'on duty' (unless exempted), the driver cannot undertake any fare paying journeys without CCTV operating, even if the passenger requests or insists that it is switched off, unless there is an extreme medical emergency.
  
  
• The driver will be able to switch off the CCTV when the vehicle is 'off duty' and being used solely for social and domestic purposes - i.e. not being used for paying passengers.

We would publish a privacy policy detailing how and why the CCTV information would be accessed. To summarise:

• We, the council, would be the data controller
• Notices advising CCTV must be displayed in / on the vehicle
• Only authorised officers of the council and the police would have access to the data. Not the driver or proprietor.
• The CCTV would only be accessed and downloaded in limited circumstances
• CCTV would capture images and only record sound (voices) if either the driver or the passenger pressed a 'panic button'

Cost and supply of CCTV

The approximate cost of commercially available CCTV systems which meet the proposed technical specification is in the region of £400 to £800 per vehicle. This is dependant on the number of cameras required. A larger vehicle with seating set in rows may require more than one camera. Installation costs vary, however, on average, the cost is approximately £120 to £200 per vehicle.

Our Licensing Team is engaging in conversations with a number of external suppliers of CCTV and recording systems. This is with a view to securing suppliers who may offer reductions in unit prices for drivers licensed by us. These discussions will continue throughout the consultation period.

Proprietors should be aware that the initial cost of the CCTV system may be recoverable as an allowable business expense for tax purposes.

Licensed drivers know how much more expensive insurance is for a licensed vehicle. They may be interested to know that some insurance companies give up to 15% discount (a saving of around £200 to £250 per year) if:

• The vehicle is fitted with a forward-facing camera in addition to interior camera(s)
• The recorded data meets the requirements to be used for legal (court) purposes

In consideration of the above two points, the initial cost of purchasing and installing CCTV could be recoverable over a period of time. But in the current economic climate, we understand that the initial cost can be a burden to some.

Have your say

The survey and consultation closed on 2 February 2024.

Thank you to everyone who responded. We will collate the information gathered during the consultation and present it to the Licensing Committee later in the year.

Next steps

We are analysing your responses following the closure of the consultation.

Once analysed, the results will form the basis of a justification document (in accordance with The Home Office ‘Surveillance Camera Code of Practice’) where the merits of CCTV mandated as a condition of licence will be examined based on the evidence. The justification document must outline whether or not:

• Implementing CCTV is in pursuit of a legitimate aim
• ii) Implementing CCTV is necessary to meet a pressing need
• iii) Implementing CCTV is proportionate
• iv) Implementing CCTV is effective

The Licensing Committee will fully consider the survey results and consultation responses before making their recommendation to Full Council.