UK Watchdog Advocates for Improved Data Governance in Live Facial Recognition Use
The United Kingdom’s data protection regulatory body, known as the Information Commissioner’s Office (ICO), has recently called for police forces that employ live facial recognition (LFR) technology to enhance their data governance practices. This appeal comes at a time when more law enforcement agencies are beginning to implement LFR, often lacking prior experience in deploying such technology in public settings.
Emily Keaney, who serves as the deputy commissioner for regulatory policy at the ICO, shared her insights in an article published on August 18. She noted that several police forces are increasingly making use of LFR technology, even experimenting with innovative methods like operator-initiated facial recognition. This particular approach allows officers to stop individuals on the street and cross-reference their identities against a watchlist. In her statement, Keaney emphasized the dual nature of this technology: while there are compelling arguments suggesting that LFR can help law enforcement in preventing and detecting criminal activity, it also carries significant risks. A false match, she pointed out, can lead to undesirable outcomes, including wrongful intervention, unfounded accusations, or even wrongful arrests.
In her discussion, Keaney made it clear that ensuring the lawful and proportionate application of LFR is imperative. This includes establishing robust oversight, accountability, and safeguards that align with data protection laws. In her current efforts, the ICO has conducted audits on several police forces to assess their use of LFR technology. She recommended that police forces across England and Wales utilize the findings from these audits to improve their approach to data protection governance.
Upon reviewing the audit results, Keaney noted discrepancies in compliance rates among the five police forces that were analyzed. Although compliance rates for LFR are higher in comparison to retrospective facial recognition (RFR), there remain crucial areas in need of immediate improvement. The ICO highlighted several key recommendations for police forces:
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Senior Oversight and Training: It is essential to establish clear supervisory structures, accountability measures, and comprehensive training for personnel operating facial recognition technology (FRT).
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Accurate Record-Keeping: Police agencies must maintain transparent records detailing what personal information is being utilized, its origins, how it is utilized, and the parties with whom it is shared.
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Appropriate Sources for RFR Images: Agencies need to ensure that RFR images are obtained from appropriate sources and are not retained longer than necessary.
- System Accuracy: There must be regular checks on the accuracy of facial recognition systems to mitigate the risk of unfairness or bias in their application.
Among these recommendations, ensuring the accuracy of facial recognition systems is of particular importance. A Home Office report released in December 2025 revealed some concerning findings, indicating racial bias within RFR systems employed by law enforcement agencies. The report suggested that under certain conditions, the facial recognition algorithms tended to inaccurately include certain demographic groups in their search results. In reaction to these findings, Keaney underscored the ICO’s requirement for "urgent clarity" on this issue, which would facilitate a comprehensive assessment of the situation and guide the agency’s next steps.
In an encouraging development, the ICO reported that police forces appear “willing to engage and make changes” in alignment with the audit findings. This responsiveness indicates a growing awareness of the need for stronger data protection governance, which is deemed essential for fostering public trust in the use of facial recognition technology as a tool for policing.
Despite the ICO’s positive interactions with law enforcement, rights groups have raised concerns over the potential misuse of such technology. They have periodically advocated for stronger legislative safeguards to be implemented before facial recognition technology sees widespread adoption within police operations. It is worth noting that the application of LFR in public spaces is largely restricted by the European Union’s AI Act, which further reflects the ongoing complexities surrounding the use of facial recognition technology in law enforcement.
As police forces continue to experiment with and implement LFR technology, the UK’s ICO remains dedicated to ensuring that there are adequate protections in place. With the potential for profound implications on individual liberties and public trust, the conversation around the ethical use of facial recognition technology is more critical than ever.