Europaudvalget 2020-21
EUU Alm.del Bilag 650
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FACT SHEET
EU FISHERIES CONTROL COALITION
Remote Electronic Monitoring and Privacy:
Facts, solutions and benefits
Remote Electronic Monitoring is a tried and tested technology that supports sustainable and
transparent fisheries management.
Even so, when introducing
REM with cameras, it is not
uncommon that vessel operators and crew are uneasy about how this will impact their day to day
operations, particularly crew privacy. Addressing these concerns proactively is recommended,
including ensuring a transparent and trustworthy framework of data access and ownership
which protects fishers’ commercial confidentiality. This has been achieved successfully in other
countries in the past. The cameras are not constantly recording, but are triggered by sensors that
initiate recording during times of deploying or hauling fishing gear and sorting the catch. The
cameras are designed to operate only in the working areas of the vessel, i.e. where the nets are
coming on board and where the fish are being sorted, in order to see what is being caught and
discarded. The cameras do not record faces and they are not operational inside the living quarters
of the vessel, meaning crew privacy is secure. It is also noteworthy that CCTV is commonplace in other
industries as well as in public places.
Remote Electronic Monitoring (REM) has been proposed in the revision of the EU fisheries control system
as the effective way to overcome gaps in the implementation of the Common Fisheries Policy (CFP). REM,
including Closed-Circuit Television (CCTV), has been trialled in various European fleets for more than a decade
to strengthen fisheries monitoring and support better stock assessments. In addition, REM is mandated in
other countries such as Australia, Canada and the USA, making it a well-proven and mature technology.
Both from a policy and business perspective, the gaps observed in the implementation of the Landing
Obligation (LO) and technical measures relating to the bycatch of sensitive species justify the large-scale
adoption of cameras in European fisheries. While at-sea human observer programmes have traditionally
produced the most accurate data on discards, REM is a scalable, modern and a much more cost-effective
method to control EU fisheries and verify self-reported data.
However, one perceived obstacle concerns privacy of the crew. This paper addresses commonly held privacy
concerns associated with REM, analysing their causes, highlighting existing solutions and best practices, as
well as common misconceptions. In doing so, it demonstrates that privacy should not be considered an
obstacle to REM deployment in European fleets, as the objections are either unfounded or solutions exist
that reconcile data protection and privacy rights with these effective electronic monitoring tools.
Why?
The rationale behind REM and CCTV in European fisheries
The rationale for the introduction of CCTV into EU fisheries is chiefly the current lack of compliance with
fisheries regulations. Currently, non-compliance with the LO is widespread
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and insufficient information is
collected regarding bycatch of marine mammals.
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As the actual rates of discards are not known, fisheries
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scientists are provided with incomplete data of the actual harvest rates, which impacts the quality of stock
assessments.
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This can, in turn, allow Total Allowable Catches (TACs) to be set at unsustainable levels,
contributing to unsustainable and inequitable fisheries. These implementation gaps in monitoring and
compliance in European fisheries highlight the need for an overhaul to fisheries control. REM with CCTV is
an effective tool to overcome the challenges of monitoring not only the LO, but also interactions with marine
mammal bycatch and in providing more complete fisheries data.
For some, it appears to be a culturally sensitive issue to deploy CCTV.
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While the extent to which the
technology is used varies across Member States, it has become standard practice to safeguard property
and people using cameras, as well as public authorities using CCTV for control purposes in a number of
other sectors, including in abattoirs, waste management sites and for controlling drive time and rest breaks
for transport lorries.
The tried and tested solutions offered by REM demonstrate the added value of this technology to support
a fisheries management system that successfully promotes environmental sustainability, whilst furthering
the economic viability of the fishing industry.
What?
From the need for REM programmes to how to design them
While there is evidently a need for improved fisheries controls in EU seas, vessel operators and crew are
sometimes uneasy about how REM will affect their day to day operations. Fishers sometimes see REM with
cameras as an intrusion
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by public authorities. This relates to a personal opposition to being recorded in
principle,
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as crews will often not only consider fishing vessels as operation sites, but understandably also
as their temporary “home” while at sea.
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Some fear that REM could lead to trade secrets being exposed
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or impact business privacy.
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Others have voiced concerns over possible manipulation or misuse of video
footage to discredit fisheries.
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To a large extent, these concerns are based on common misconceptions
about the technology and the retention of the data.
Firstly, there should be a clear understanding from the outset of the purpose of REM, as the data is solely
intended for monitoring and compliance purposes. This means that the objective of REM is to monitor the
fishing operation, i.e. the vessel’s catch and how it is being handled once on board. Conversely, the purpose
is neither to monitor the entire vessel nor to record people on board individually. This is reflected in how
the cameras are positioned.
The typical positioning of cameras on a vessel, all of which record the catching or sorting areas of the vessel (i.e. not in the private
areas of the vessel). Photo credit: Archipelago Marine Research Ltd., 2012.
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Monitoring programmes focus on fisheries activities, which may in turn indirectly lead to the collection of
private data, such as partial footage of the crew. EU citizens enjoy specific rights when it comes to their
privacy which are granted by the EU General Data Protection Regulation (GDPR), and any implementation
of video monitoring schemes must be GDPR-compliant. Nonetheless, many of these concerns can be
addressed through effective set-up and management of REM operating systems.
How?
Reconciling data protection and privacy rights with REM through effective set-
up and management systems
From a privacy perspective, the set-up and management of REM operating systems give rise to two questions:
1) what footage is acquired and 2) how is the footage used once collected?
In those cases in which REM footage may capture recognisable individuals on a fishing vessel, it is essential
to comply with GDPR rules and protect privacy. There are two solutions to this: avoiding personal data
collection wherever possible or, where this is not feasible, irreversibly anonymise all personal data recorded
to prevent any identification of individuals by way of technology.
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Avoiding personal data collection boils down to monitoring the technical processes without recording the
crew in a way that would make them identifiable.
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In practice, this means adjusting the location, range and
angle of cameras on board, as well as making information available to the crew about the systems installed
on their vessels. Standard operating practice is to limit the video monitoring to a minimum time,
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usually
recording only the landing, sorting and processing of the catch, e.g. by using sensors on winches and sorting
bands to switch cameras on and off.
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In working areas, the CCTV recording angles can be adjusted to
prevent the identification of workers. This, in turn, limits the opportunity for crew to be caught on camera
indiscriminately. Naturally, the cameras only cover the operation areas and exclude other locations, such as
living areas. REM also provides fishers with more privacy on board in comparison to human observers, as
it focuses on catching and handling zones only, whereas human observers have access to the whole vessel
and remain on board for the duration of the fishing trip.
When it comes to anonymisation, technological solutions can deliver on personal data protection at the
recording stage. Software solutions exist today that are capable of irreversibly anonymising the individuals
operating in the monitored areas at the time of recording, for instance, by means of pixelation.
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According
to technology companies providing CCTV recording services for fisheries, improved machine learning will,
in the near future, further improve the technological anonymisation solutions offered to protect the data
privacy of crew members.
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Cameras are positioned so that they only record the catching or sorting activities. Photo credit: Environmental Justice Foundation
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When dealing with data privacy, consent and clear protocols are key. A best practice reported by one fishing
association was to adopt a fully transparent communication with the crew. On these vessels, it is required
that all areas which are recorded are screened on a video control panel, so that the crew knows what is
being recorded in which working area.
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Comfort levels of working whilst being monitored by a camera also
relate to a question of habit and trust. In this regard, studies have shown that there is a big difference in
the level of acceptance between REM-experienced fishers, who are mostly positive, and those without any
first-hand experience with REM.
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Many studies suggest that the crew simply become acquainted with the
presence of cameras during trials and operation.
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Consent, however, relates to broader considerations than data collection methods. The overarching purpose
and data ownership impact the acceptance of CCTV on board vessels, as well as the trust between fishing
operators and public authorities. Many fishers acknowledge that having cameras on vessels is not a problem
in itself, but rather the concerns relate to having a clear set of agreements and policies on who has access
to the information and how it can be used. The issues of data access and ownership have been successfully
addressed in various countries that have introduced REM. In Australia and New Zealand, for example,
the footage is automatically encrypted at the time of recording and access is only granted to competent
authorities. As the concerns will often relate to commercial confidentiality and potential damage to a fisher’s
reputation, the introduction of REM needs to be accompanied by clear objectives and data management
policies, e.g. imagery retention timeframes, privacy provisions, delivery of REM information from vessel to
review facility. Clear and transparent rules around design, transmission, treatment and storage of data are
needed to provide assurances regarding the benefits of REM.
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References
1
European Fisheries Control Agency, 2020. Evaluation suggests non-compliance with the Landing Obligations in certain fisheries in the
North Sea and North Western Waters. Retrieved from: https://www.efca.europa.eu/en/content/pressroom/evaluation-suggests-non-
compliance-landing-obligations-certain-fisheries-north-sea
ICES, 2018. Bycatch of small cetaceans and other marine animals – review of national reports under Council Regulation (EC) No.
812/2004 and other information. https://doi.org/10.17895/ices.pub.4514
ICES, 2018. Cod (Gadus morhua) in subdivisions 22–24, western Baltic stock (western Baltic Sea). https://doi.org/10.17895/ices.pub.4377
Michelin et al., ‘Catalyzing the Growth of Electronic Monitoring in Fisheries’ (2018) 46.
Plet-Hansen et al., Remote electronic monitoring and the landing obligation – some insights into fishers’ and fishery Helmond opinions,
Marine Policy 76 (2017) 98–106.
Mangi, S.C., Dolder P.J., Catchpole, T.L., Rodmell, D., de Rozarieux, N., Approaches to fully documented fisheries: practical issues and
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NOAA. “Second National Electronic Monitoring Workshop.” (2017).
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Europêche, Europêche position on the EU Fisheries Control System, Brussels, 5 December 2017.
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Marine Policy 76 (2017) 98–106.
Serbina Tatjana, Legal Opinion on Video Monitoring on Fishing Vessels with Special Focus on Other Comparable Cases Requirements,
concerns, solutions, March 2019, Commissioned by Our Fish.
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Answer provided by a representative of the company AnchorLab, specialized in EM in fisheries, to a question related to data privacy
and REM, during the Commission’s seminar on the EU Landing Obligation organized on 14.6.2019: “Blacking out of people can be done
permanently and irreversibly while recording”.
Information provided by EM-solutions provider SatLink to questions related to data privacy and REM, during a Commission seminar on
the EU Landing Obligation organised on 14.6.2019.
WWF, confidential interview with a national fisheries industry association conducted on 15/04/2020.
Plet-Hansen et al., Remote electronic monitoring and the landing obligation – some insights into fishers’ and fishery Helmond opinions,
Marine Policy 76 (2017) 98–106.
S., Zimmerman, C., et al., 2019. Electronic monitoring in fisheries: Lessons from global experiences and future opportunities, Fish and
Fisheries 2020; 21:162–189.
Plet-Hansen, K. S., Bergsson, H., Mortensen, L. O., Ulrich, C., Dalskov, J., Jensen, S. P., & Olesen, H. J. (2015). Final report on catch quota
management and choke species – 2014.
S., Zimmerman, C., et al., 2019. Electronic monitoring in fisheries: Lessons from global experiences and future opportunities, Fish and
Fisheries 2020; 21:162–189.
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Van Helmond, A.T.M., Mortensen, L.O., Plet-Hansen, K. S., Ulrich, C., Needle, C.L, Oesterwind, D., Kindt-Larsen, L., Catchpole, T., Mangi,
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