Safe City operation | Letters to the Editor

Healthy debate was generated by MaltaToday's article on facial recognition CCTV, on matters related to privacy and civil liberties

The article ‘Paceville is test case for facial recognition CCTV that could be deployed nationwide’ (MaltaToday, 3 December 2017) has generated healthy debate on matters related to privacy, human rights and civil liberties and I would like to make a few clarifications on the matter.

Technological innovation accelerates social and economic progress to improve the quality of life, but can also weaken or interfere with the citizens’ right to privacy and freedom if used inappropriately. That is the reason why the EU and the Member States’ laws and regulations go to a significant extent to put safeguards against potential abuse, and that at a European level the right to privacy is considered a human right.

The article has generated unnecessary concern because one could easily arrive at the wrong conclusions based on what was said and written. It also prompted the IDPC to contact me to seek more information on what was reported. The full context and an explanation was given to the IDPC and other interested parties.

A clear distinction needs to be made between technology and capabilities, and operational objectives. State-of-the-art communications and video surveillance technology can be used to put in practice scenarios as were reported in the article. Indeed, it is technically possible nowadays to operationalise systematic mass video surveillance and deploy wide-scale biometric facial recognition, and equip a van as a mobile control centre for policing purposes as was explained in the article.

For a proof-of-concept public CCTV operation to be put into practice, a stakeholder or stakeholders that will take the responsibility of carrying out video surveillance needs to be roped in to the project. The company that has been set up (Safe City Malta Ltd) is meant to act as a technology enabler, in collaboration with Huawei, and will not carry out video surveillance itself.

Once a stakeholder is formally on-board the project, the scope and requirements of the surveillance operation will need to be defined. Such an entity, acting as a Data Controller, is obliged to carry out a Privacy Impact Assessment, especially since public CCTV surveillance falls under the category of high-risk data because of lack of consent from data subjects and the potential mass accumulation of data. This would be done with the full support and involvement of the Data Processor, which in this case would be the company that has been set up.

Under EU General Data Protection Regulations, the Data Processor also has significant obligations at law which must be satisfied before any data processing operation can commence. The assessment must also prove that processing of personal data is consistent with Data Protection by Design and by Default.

The planned implementation and operation must satisfy all legal requirements, and ensure that before any data processing of personal data begins, even on a proof-of-concept basis, the final solution design according to the approved requirements of the planned operation must tick all the boxes from a data protection and privacy standpoint. The nature of this project will also mandate careful consideration of Human Rights and must satisfy a test of acceptability. The amount of interference to the right of privacy must have legal justifications, must be proportionate to the target end objective, and only go as far as is required to obtain such results.

It is planned that in the coming months the building blocks, in terms of hardware and software, are commissioned such that technical training at an engineering level can follow without undue delay. This will also enable academic projects to move forward as the platform provides many opportunities for such work in many areas related to radio telecoms, private cloud and enterprise networking infrastructure, as well as advanced video technology. Commissioning of such infrastructure will not involve any cameras in Paceville or any public surveillance operation.

The process described above in terms of getting the green light for a surveillance operation will kickstart once stakeholders who would carry such video surveillance on a proof-of-concept basis in a locality such as Paceville or other approved location are engaged. That approval process might require certain solution design changes along the way, as no operation will start unless all legal requirements are met.

Even from an academic research or experimental software development perspective, all proposed projects need to be in line with applicable research committees’ policies of the institutions involved, and must fulfil all data protection guidelines and regulations.

Malta is a technologically advanced nation. This project is a key opportunity for Malta to showcase how state-of-the-art video surveillance can be put to good use while fully meeting privacy regulations and respecting human rights.

Joseph Cuschieri

Director, Safe City Malta


Is it murder or an assassination?

How to refer to Daphne’s gruesome end?

Was it murder or assassination? An assassin kills, or is contracted to kill, out of a political motive. That is the meaning assassin has evolved to.

The word is of Arabic origin, referring to an extremist sect of Muslims whose members were sent out by their Grand Master from his fortification in Iran to kill leaders of the Sunni.

During the Crusades, they went after Christians with equal gusto.

At the time it meant fundamentalist, a term which one might suppose has now come full circle. So what began as a murder driven by religious faith, has now come to mean one driven by political credo. For sometimes a blurred, if not overlapping, thin line divides the two.

Joe Genovese



Virgin birth of the Christ

The Christian belief in the virgin birth of Jesus is derived from primitive myths about the virgin birth of gods and national heroes. Mercury was born of the virgin Maia; Attis of the virgin Nana; Horus of the virgin Isis; and Romulus of the virgin Rhea Sylvia.

In his book God is not great, Christopher Hitchens observed that Jesus made “large claims for his heavenly father but he never claimed virgin birth. Mary herself appears to have no memory of the Archangel Gabriel’s visitation.”

Thomas Jefferson predicted that “the day will come when the mystical generation of Jesus in the womb of a virgin will be classed with the fable of the generation of Minerva in the brain of Jupiter.”

John Guillaumier

St Julian’s