Non-confidential facts and advice to the Deputy Mayor for Policing and Crime (DMPC)
1. Introduction and background
1.1. A video or ‘smart’ doorbell is an internet-connected doorbell that notifies the smartphone or other electronic device of the homeowner when a guest arrives to the entrance of the door. It activates when the guest presses the button of the doorbell, or alternatively, when the doorbell senses a guest with its built-in motion sensors. The smart doorbell allows the home owner using the smartphone app to watch and talk with the guest by using the doorbell's built-in high-definition infrared camera and microphone
1.2. Working with an academic institution will effectively highlight the success of such devices but also such initiatives. The MPS will be employing the services of the Director of the Centre for Future Crime at the Jill Dando Institute of Security and Crime Science, part of University College London. They will be producing an academic primary evaluation of this initiative in the form an academic research paper.
2. Issues for consideration
2.1. Video doorbells roll out would be focused on victims at a high risk of being repeat victims and from a pre-defined victim type, supporting some of the most vulnerable households in London from a particularly impactive crime. The preventative nature of the project helps to reduce demand and allow resources to tackle other issues of high risk and high harm across London.
3. Financial Comments
3.1. The roll out is at zero cost, with no financial impact on the MPS, not taking into account MPS staff/officer time on the project. The financial sponsorship includes any installation costs paid for by Ring as part of this agreement.
4. Legal Comments
4.1. Clause 4.8 of the MOPAC Scheme of Delegation requires the Deputy Mayor for Policing and Crime to approve all inward donations and sponsorship £50k and above in value. This initiative will exceed this £50k threshold.
4.2. The arrangement will be formalised by the documented approval of a S.93 sponsorship agreement. Publication of the agreement will be under the Elected Local Policing Bodies (Specified Information) Order 2011.
4.3. Based on previous advice to the MET third party contracts team, DLS have approved the legal position.
5. Commercial Issues
5.1. Ring is an approved member of Police CPI ‘Secured by Design’ Scheme and would be suitable to work with the MPS on this project. Ring are currently the only Secured by Design (SBD) member company with a video doorbell on the police preferred specification list. There are other Secured by Design member companies who manufacturer video doorbells but they do not currently have a video doorbell on the approved police preferred specification of Secured by Design.
5.2. The ‘MPS Ethical Considerations for Revenue Generation’ approach was applied to this agreement and MPS Commercial have confirmed that it covers this proposal. The impact on the market of accepting these goods was considered during the ‘commercial assessment’ and MPS Commercial have judged that this non-exclusive arrangement would not distort the market nor provide the supplier with any significant benefit above that of being approved by Police CPI Ltd.
6. Public Health Approach
6.1. This proposal focuses on crime prevention and improving safety. The video doorbells roll out would be focused on victims at a high risk of being repeat victims and from a pre-defined victim type, supporting some of the most vulnerable households in London from a particularly impactive crime. The preventative nature of the project helps to reduce demand and allow resources to tackle other issues of high risk and high harm across London.
7. GDPR and Data Privacy
7.1. The MPS is subject to the requirements and conditions placed on it as a 'State' body to comply with the European Convention of Human Rights and the Data Protection Act (DPA) 2018. Both legislative requirements place an obligation on the MPS to process personal data fairly and lawfully in order to safeguard the rights and freedoms of individuals.
7.2. Under Article 35 of the General Data Protection Regulation (GDPR) and Section 57 of the DPA 2018, Data Protection Impact Assessments (DPIA) become mandatory for organisations with technologies and processes that are likely to result in a high risk to the rights of the data subjects.
7.3. The Information Assurance and Information Rights units within MPS will be consulted at all stages to ensure the project meets its compliance requirements.
7.4. The supplier will hold the householder registration data, not the MPS. Householders may opt into updates on local policing issues. Opting in will allow householder details to be added to the MPS Airspace database. The continuation of a regular database review will ensure their details remain correct and confirm they consent to continue to ‘opt in’ for further contact.
7.5. The MPS will not have access, nor the facility to access, any recorded images or video from the ring devices without the resident’s specific consent. Nor will the MPS have access to any live footage from the devices. If the MPS wished to obtain any footage for policing purposes, this will be dealt with in the same way as obtaining footage from any private CCTV system, i.e. during the course of a criminal investigation.
7.6. The design out crime team and supplier will record and review anonymous statistical data. This would be to confirm if the device is on and working and being used.
7.7. The project therefore does not use currently personally identifiable data of members of the public, so there are no current GDPR issues to be considered. If the project uses personally identifiable data of members of the public at a later date DPIAs will be completed as needed.
8. Equality Comments
8.1. Selection of individual households will be by use of victim and burglary risk analytical data. The households selected would be part of a randomized sample from a list of those with identified risk factors. The risk factors being based on long term burglary ‘hotspot’ data, identified by Met Intelligence team. The nature of the randomized sample would be decided by the academic institution to ensure impartiality, fairness and maintain the integrity of the end product research piece.
8.2. The provided device does have some functionality linked to a smart phone. It could be said that certain persons, with protected characteristics, are more likely than others, not to own a smart phone. The device will however still provide the necessary benefits to those provided with it, without a smartphone device. No person will be discriminated against, due to the fact that they do not own a smartphone and they will still be offered a device. Selection of residential properties, to have a device installed, will be from a variety of intelligence information and so not discriminating against protected characteristics’.