Sunday, 12 May 2013

No RBI Guidelines for ATM CCTV Recording in India

There are no Reserve Bank of India guidelines for video recording of ATM transactions in India. That means, CCTV recording or even ATM pin hole camera recording of ATM transactions is not compulsory. Whatever little recording takes place at present is purely a voluntary effort on the part of banks or their ATM vendors. I got this information in a reply to my RTI application filed with Reserve Bank of India. The RTI application was made to know the Reserve Bank of India (RBI) guidelines for security of on-site and off-site bank ATMs in India. RBI's reply is kind of shocking. Practically, there are no guidelines and the security of ATMs has been left to the discretion of banks. Let me give the details: There are no RBI guidelines for recording of ATM transactions via a pin hole ATM camera or a CCTV camera monted on a wall around the ATM machine. Resultantly, only God knows how many bank ATMs in India are functioning without a built-in camera and / or a CCTV camera fitted around. There are no RBI guidelines for preserving the ATM camera / CCTV recording for a minimum period of time. Some banks (vendors) "preserve" recordings for 1 month or 3 months as per their own sweet will, while others don't. Instances of recording equipment like hard disk being "full" or faulty are rampant. Since there are no RBI guidelines, in case of failed ATM transactions, banks do not provide video recording to the Banking Ombudsman and easily get away by saying something like "ATM camera / CCTV was not working on that day". Read more below...

My application for information under RTI Act was not addressed to any particular department of Reserve Bank of India in particular. RBI in its own wisdom, directed some queries to Department of Banking Operations & Development (DBOD) and some queries to Department of Banking Supervision (DBS).
 
Information given by Department of Banking Operations and Development (DBOD) of Reserve Bank of India
(This department is responsible for regulation of Banking System in India)

Reserve Bank of India Guidelines for ATM CCTV Camera Recording
 
Question: Norms prescribed by Reserve Bank of India for placement of cameras and quality of video / picture recording by in-built ATM camera and CCTV camera in the ATM cabin or near the ATM in case of open ATM in respect of on-site and off-site bank ATMs in India.

Reply: We have not issued any specific guidelines in this regard. (DBS has not issued any guidelines either)

Question: Norms prescribed by Reserve Bank of India for preparation, despatch and delivery of ATM / Debit Cards by banks in India to their customers

Reply:  We have not issued any norms for preparation, despatch and delivery of ATM / Debit Cards by banks in India to their customers. (DBS has no information in this regard)

Question: Norms prescribed by Reserve Bank of India with regard to the physical features of ATM / Debit Cards issued by Banks in India.

Reply: We have not issued any norms with regard to the physical features of ATM / Debit Cards issued by Banks in India. (DBS has no information in this regard)

Question: Norms prescribed by Reserve Bank of India for access to ATM machines' inner parts, CPU, card reader, network cable, etc. by service engineers particularly whether the service engineer can visit and service the ATM alone or should be accompanied by an official of the concerned bank in India

Reply: We have no information in this regard. (DBS too has no information in this regard)

Information given by Department of Banking Supervision (DBS) of Reserve Bank of India
(This department is responsible for supervision of Banking System in India)

Reserve Bank of India Guidelines for Security of Bank ATMs

Question: Norms prescribed by Reserve Bank of India for physical security of bank ATMs in India

Reply: This department has not prescribed any norms in this regard. However, some suggestions have been forwarded by us to the banks for enhancing security arrangements at the ATMs. Disclosing these suggestions regarding security arrangements at ATMs of banks would compromise their security and therefore the same are exempt from disclosure in terms of Section 8(1)(d) of the Right to Information Act, 2005.
(I have personally lost faith in Reserve Bank of India's ability to be an effective banking supervisory authority after reading this reply that was signed by Mr.  G. Jaganmohan Rao, Chief General Manager-in-charge of the Department of Banking Supervision. I would like to request the heads of Central Banks all over the world to note this reply of Reserve Bank of India)(Click here for my article on Physical Security of ATMs in India)

Question: Norms prescribed by Reserve Bank of India for installation of on-site and off-site bank ATMs in India in terms of requiremenet of construction of cabin, identification of physical spot, etc.

Reply: This department does not have the information. (Reserve Bank of India does not have any answer to this question)

Question: Norms prescribed by Reserve Bank of India for hardware and software of ATM machines to be used by banks in India

Reply: This department does not have the information (Reserve Bank of India does not have any answer to this question)

Question: Norms prescribed by Reserve Bank of India for preservation of footage recorded by ATM camera / CCTV camera

Reply: This department has not prescribed any norms in this regard. However, some suggestions have been forwarded by us to the banks for enhancing security arrangements at the ATMs. Disclosing these suggestions regarding security arrangements at ATMs of banks would compromise their security and therefore the same are exempt from disclosure in terms of Section 8(1)(d) of the Right to Information Act, 2005.

Question: Norms prescribed by Reserve Bank of India for logical security of  Bank ATM operation by customers in India such as software interface with the customer, flow of transaction, security related suggestions to the customer during the transaction, security features built into the transaction interface, retraction of cards in roller-type ATM slots in case of failed authentication, etc.

Reply: This department does not have the information. (Reserve Bank of India does not have any answer to this question)

Question: Norms prescribed by Reserve Bank of India for reconciliation of day-end balances, physical cash balances, refilling of cash balances, periodical surprise checking of physical cash balance at bank ATMs in India

Reply: This department does not have the information. (Reserve Bank of India does not have any answer to this question) 

My expert advice

Well, I am only able to give a spiritual advice in this state of banking regulation and supervision in India. Whenever you do a transaction at a bank ATM in India, pray to your God before and after the transaction.

Also see: Arbitration and Appeals for Bank ATM Complaints




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All information given in this blog is obtained from sources in the public domain, RTI applications, discussions with bankers, bank customers in India and also with some employees of Reserve Bank of India having knowledge of the working of various Offices of Banking Ombudsman in India. All information in this blog is presented on a best effort basis and is not claimed to be complete information on any of the subjects covered in this blog. Use of any information given in this blog is purely voluntary on the part of the readers. Author of this blog does not assume any responsibility for any action of the readers related to any matter discussed in this blog or any consequences thereof. Readers of this blog are advised to consult a legal practitioner before taking any action related to any matter discussed in this blog.