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Exclusive: Behaviour and protest monitoring a part of Jabalpur Municipal Corporation’s surveillance tender

A tender by the civic body in Jabalpur, Madhya Pradesh seeks an integrated surveillance system for monitoring ‘behaviours’, controlling protests, more

What’s the news?

The Jabalpur Municipal Corporation has issued a tender to implement a surveillance system in the city, whose objectives include monitoring protests and behaviour of people. The system must facilitate the police to “track and control the movement of all the vehicles running on ground,” the tender states. It goes on to say that the system should allow taking “feeds from other surveillance mediums like mobile camera feed and body-worn cameras”, for better interoperability. 

You can view the full Request For Proposal (RFP) document here

Why it matters: JMC is looking for a “complete end-to-end solution for surveillance application,” and it should be scalable to “meet the growing demands of the city,” the tender says. This suggests that JMC is inclined to increase surveillance coverage in the city. With limited data protection rights in India, rising surveillance is a cause for concern. A report by Comparitech states that Delhi, Chennai and Mumbai are among the most surveilled cities in the world, outside of China, which is the most surveilled country. It also states that Indore has the highest number of CCTV cameras per 1000 people in the world (excluding China) at 62 cameras per 1000 people. In the light of rising surveillance, it is important to keep a check on how and for what purpose surveillance tech is being deployed. 


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What is the purpose of this tender?

Gajendra Singh, E-Gov Manager, Jabalpur Smart City Limited told Medianama “This tender is not for surveillance. The Central Government has a mission to reduce India’s AQI by controlling pollution. In this regard, we’re implementing some Public Announcement (PA) systems. The motive is to reduce congestion in high traffic and crowded areas by installing PA and surveillance systems.” He also informed Medianama that the tender was prepared by PwC in collaboration with the JMC.

However, in addition to traffic management, the tender mentions several other objectives and use-cases:

  1. Facilitate behaviour monitoring and public safety – The surveillance system should “facilitate the Police Department officials serving on the field/ground duty with surveillance equipment for Public Safety, traffic management and behaviour monitoring”, the tender states. What “behaviour monitoring” means has not been defined. Can a person smoking a cigarette be said to have ‘bad behaviour’? Including such vague words in the tender widens the scope of surveillance as this could potentially mean that every person will be monitored to check if their behaviour is ‘good or bad’. For instance, UP’s proposed artificial intelligence-based CCTV cameras may track you if you’re smoking in a place with ‘women-heavy footfall’.
  2. Surveillance for public events and protests – One of the objectives of this tender is to provide police the ability to monitor protests using surveillance systems. The surveillance system should “Facilitate the Police Department with in-vehicle surveillance system suitable for protection of high security areas, public events, protests, critical infrastructure, disaster sites etc.”, the tender states. But when asked if this is a good idea, Anushka Jain, Associate Policy Counsel, Internet Freedom Foundation said “The assumption that CCTV cameras lead to security needs to be questioned. Such claims should be made only when relevant data is available. There is nothing that shows using CCTVs or Facial Recognition Systems (FRS) will lead to better security. This assumption is itself faulty.” With more CCTV cameras, the scope for using facial recognition increases. Although the tender does not talk about FRS, it does mention that “It should be possible to integrate the Surveillance System with 3rd-party software, to enable the users to develop customised applications for enhancing the use of video surveillance solution”. Hence, it’s safe to assume that it will be possible to integrate these CCTV cameras with FRS. In the past. FRS have been used to crackdown protests in India and abroad. For instance, a police commissioner informed Indian Express that FRS was used to arrest 137 people in “Northeast Delhi riots”.

    When asked about her thoughts on this provision, Vidushi Marda, Senior programme officer at Article 19 said: “In the absence of robust legal protections for why, where, when and by who data can be collected, stored, analysed and used – this objective in the tender is essentially opening the door to a data collection exercise at scale, without a specific purpose”.

    “This is indicative of a much wider trend we’re seeing vis-a-vis technology and governance. The use of technical systems is justified in the public eye in the context of disasters, public security etc but the reality is that these systems will be used to collect massive amounts of data, in the absence of any legal justification of the same”, she added.
  3. Track and control the movement of vehicles –  The police want the ability to track every vehicle in cameras’ sight. This tracking can reveal where a vehicle is going, who’s sitting in the vehicle, who owns the vehicle and even what the person in the vehicle likes/dislikes and where they work and hangout. For example, if the CCTV identifies a car that takes the route to Medianama’s office on weekdays, it is likely to belong to someone who works at Medianama.

    When asked if there are any laws to protect people’s sensitive data, Jain said “The IT act talks about sensitive data. Section 43 of the IT Act is framed in such a way that you have to show some harm caused to get any kind of redressal. However, most people don’t even know that they are being surveilled, so it’s difficult to show harm. And Sensitive Personal Data or Information [SPDI] Rules 2011, which talk about the protection of sensitive data only apply to private actors”. Hence, they do not provide enough protection against data recorded and analysed by government controlled CCTV cameras.
  4. Conduct analysis for continuous improvement of city operations – The key word here is “analysis.” This does not mention what kind of analysis will be performed and on whom, or what is meant by “continuous improvement”. This statement could mean that the police will analyse CCTV cameras for identifying a thief, and it could also mean that police will go overboard to analyse every single person that it sees.
  5. Integration with existing/proposed/future third party systems – Another point of concern is that the tender asks bidders to provide surveillance systems the capability to connect to third party systems. The system applications proposed (for integration) “should have open APIs and should be able to integrate and share the data with other third-party systems already available or coming up in the near future,” the tender states. Giving third parties access to personal data of citizens is a risky move. One lapse in security can put the facial data of millions of people at risk of being hacked, stolen, leaked or misused. Moreover, integrating with different systems could also mean using advanced surveillance systems like AI enabled facial recognition and behaviour monitoring tools. Such systems have already been deployed in multiple cities like Delhi, Mumbai and Surat.

    IFF’s Jain raised concerns about the use of facial surveillance technology, “The use of Facial Recognition System (FRS) is problematic because it’s not an accurate technology. It can lead to misidentification, which can lead to unnecessary harassment of people. Secondly, the use of this technology also allows a lot of personal sensitive information to be collected and aggregated, which is worrisome.”  

More problematic provisions:

  1. Integrating social media platforms: “It should be possible to integrate social media platforms to Surveillance System to enable Jabalpur Police to track and monitor certain trending incident or crime”, the tender mentions.

    “A cursory reading suggests that “integrate social media platforms” would mean scraping and perhaps even syncing data from social media platforms to create profiles of individuals’ lives, movement, preference. This kind of integration runs contrary to so many principles of data protection like data minimisation, purpose limitation; and also represents an egregious violation of privacy, particularly in the absence of data protection laws,” Marda of Article 19 said.
  2. Body-worn cameras: This surveillance system should facilitate integration with body-worn cameras, which are often hard to spot. Where CCTV cameras are stationary, body-worn cameras can offer more flexibility in surveillance by offering the capability to record on the move and often without knowledge of the other person. For reference, below is an image of US police officers wearing body-worn cameras:

    A Body-worn camera is present above the left pocket of all police officers in the picture (Sourced from eff.org) (Courtesy: Houston Police Department) 
  3. Interoperability: The tender document mentions that the surveillance systems should not work in isolation and should have the capability to take feeds from other surveillance mediums like mobile and body-worn cameras. Moreover, the surveillance system should also allow “cross-functionality with the e-Government projects of other departments / businesses in future, the solution should be built on Open Standards”. The exchange of information between multiple systems and departments can allow surveillance on a much larger scale as many data points about a single person can be seen in conjunction with each other. Moreover, it’s not clear whether every department will have access to all the data or if access to data will be limited based on what department they’re from. For example, whether police department will have easy access to data collected by other departments like traffic department or health department or water department, is not clear from the tender.
  4. Constant surveillance: The tender document states that JMC wants to introduce the surveillance system “to provide safety and security to all the citizens of the city”. It goes on to add that “major components of the project shall comprise the installation of camera surveillance with Public Address System at identified locations to monitor, control and communicate with the citizens across the city.” The key words to note are “monitor” and “control”. This could mean authorities have limitless access to monitor citizens at all times.

Tender document on data storage and protection

  • The architecture should adopt an end-to-end security model that protects data and the infrastructure from malicious attacks, theft, natural disasters etc.
  • The Implementing Agency (IA) should make provisions for security of field equipment as well as protection of the software system from hackers and other threats. Author’s take: Although there are more such technical provisions to protect sensitive data from hackers, time and again, cases of data being hacked have come to the forefront.
  • Data will be stored in the existing Data Centre in Jabalpur under Jabalpur Integrated Command & Control Centre (ICCC)
  • 30 days storage of all the surveillance camera feeds to be stored at Data Centre and Flagged data (critical incidents) of not more than 10% of Cameras feed will be stored for approximately 90 days. Author’s take: It’s not clear what will happen to the data after 30 days or 90 days, will it be transferred to a cloud or to another server, or will it be deleted?

Growing role of ICCC: A concern

ICCC or the Integrated Command and Control Centres help in “managing operations of the smart components installed across the city.” ICCC’s in India collect data on a variety of local issues, from CCTV and traffic management data to information about water management and garbage collection. This video about Surat’s ICCC reveals the functions that ICCCs can perform and how it looks.

Below are some of the stated objectives of ICCC in Jabalpur:

  • Single source of truth for the city‘s civic functions
  • Platform with the ability to receive, intelligently correlate & share information to better predict outcomes
  • Act as City‘s emergency and disaster management platform
  • Ability to integrate multiple text, voice, data, video and smart sensors communication interfaces
  • Ability to integrate and correlate online and offline interactions
  • Advanced industrial grade cyber security features

More and more cities are taking the ICCC route by collecting and monitoring more data to ‘improve city operations’.

A case against CCTV cameras

  1. Discriminatory targeting: A sociological study reveals that “Black people were between one-and-a-half and two-and-a-half times more likely to be surveilled than one would expect from their presence in the population”, in Great Britain. Human biases often affect how and to what extent should a person be surveilled.
  2. Abuse of power: A report by ACLU states that FBI and many individual police departments in the US performed “illegal operations to spy upon and harass political activists who were challenging racial segregation and the Vietnam War”.
  3. Spying: By looking at the license plates outside a gay bar, a police officer identified a married man and tried to extort $10,000. The Integrated Command and Control Centres mentioned previously in the article can be much better at spying individuals than an individual officer.

These are just some of the ways in which CCTV cameras have been or can be misused. And with the advanced surveillance technology with the police and government today, such monitoring can only become more frequent and invasive.


This post is released under a CC-BY-SA 4.0 license. Please feel free to republish on your site, with attribution and a link. Adaptation and rewriting, though allowed, should be true to the original.

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Written By

I cover privacy, surveillance and tech policy. In my reporting, I try my best to present the most relevant facts, and sometimes add in a pinch of my thoughts.

MediaNama’s mission is to help build a digital ecosystem which is open, fair, global and competitive.

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