Wandsworth Council's use of surveillance powers primarily for blue badge investigations

Wandsworth Council's use of surveillance powers under the Regulation of Investigatory Powers Act 2000 (RIPA) was a key topic at a recent Audit Committee meeting. A report presented to the committee, titled Councils use of RIPA for the year 2025-26 [1], detailed the council's activities during the 2025-26 financial year.

The council primarily utilized these powers for investigating abuses of the blue badge scheme. The decision to employ RIPA powers is guided by the nature of the suspected offense, with the legislation prescribing unique scenarios for their use. The report indicates that surveillance was conducted under specific circumstances, with some instances falling under a formal shield and others operating under a different regime.

Paul Gigliotti, Director of Financial Services, explained that the council uses these powers sparingly and only when appropriate. The specific criteria for using RIPA powers in blue badge investigations depend on the nature of the suspected misuse. If it can be evidenced that the badge was lost or stolen, RIPA powers are deployed. However, if the badge is simply being misused, the investigation would typically proceed under a different regime. As stated in the report, Normally if it is a, we can evidence it's going to be a fraudulent act, i.e. that that badge was lost and reported lost or was stolen, then we're knowing that it's been used under that element. And if it's just been misused, we would normally do it under the other regime.

During the meeting, Councillor Jo Rigby questioned the use of facial recognition technology. Mr Gigliotti confirmed that it is not currently being used. Instead, surveillance typically involves officers on the ground using handheld equipment, cameras, or CCTV. While the specific capabilities of this equipment are not detailed, it is noted that Anything that we do and operate and the types of things we would intend to use would be documented in the application form that's being used.

The meeting also clarified the implications of operating with or without a formal shield under RIPA. The legislation allows for directed surveillance in certain circumstances, and surveillance can be carried out where we're not able to use that shield, where we think it's in the public interest to do so. And in accordance with the majority of the rules that would protect us under that shield. The key difference when operating without the formal shield is that the sanction for the offense must include the possibility of a six-month custodial sentence.

Two cases where the formal shield was used resulted in one ongoing investigation and another where a vehicle was impounded and blue badges were seized. Seven instances of surveillance were carried out without the formal shield, with outcomes detailed in paragraph 13 of the report.

[1] Councils use of RIPA for the year 2025-26 (https://democracy.wandsworth.gov.uk/documents/s126202/Councils%20use%20of%20RIPA%20for%20the%20year%202025-26.pdf)