The UK's data protection watchdog, the Information Commissioner’s Office (ICO), has called on police forces to enhance their data governance practices when deploying live facial recognition (LFR) technology. The ICO's deputy commissioner for regulatory policy, Emily Keaney, stated in an article published on August 18 that an increasing number of forces are implementing LFR without prior experience in its public use.
Keaney highlighted that some forces are even experimenting with new methods, such as officer-initiated facial recognition, where individuals are stopped in public and their faces are cross-referenced against a watchlist. While acknowledging that LFR can aid law enforcement in crime prevention and detection, Keaney also warned of significant risks, including the potential for wrongful intervention, accusation, or arrest due to false matches.
To ensure LFR is used lawfully and proportionately, with robust oversight, accountability, and safeguards compliant with data protection law, the ICO conducted audits of several police forces' use of the technology. The findings revealed inconsistencies in data protection compliance across the five audited forces, indicating that while some good practices exist, substantial improvements are still necessary.
The ICO recommends that police forces across England and Wales utilize these audit findings to bolster their data protection governance. The compliance rates for LFR were found to be higher than for retrospective facial recognition (RFR), but several critical areas still require immediate attention.
These areas include ensuring senior oversight, accountability, and adequate training for staff utilizing facial recognition technology (FRT). Forces must also maintain clear records detailing what personal information is used, its origin, how it is processed, and with whom it is shared. Furthermore, the ICO emphasized the need to ensure RFR images are sourced appropriately and not retained longer than necessary.
A crucial recommendation involves verifying the accuracy of facial recognition systems and implementing measures to mitigate the risk of unfairness or bias. This point is particularly pertinent given a Home Office report from December 2025, which identified racial bias in RFR systems used by the police. That report indicated that, under specific circumstances, the algorithm was more prone to incorrectly including certain demographic groups in its search results.
At the time of the Home Office report, Keaney had called for urgent clarity to assess the situation and determine subsequent actions. In its latest update, the ICO noted that police forces have shown a willingness to engage and implement changes based on the audit findings. The ICO maintains that strong data protection governance is vital for building the public trust necessary for FRT to be an effective policing tool. Rights groups have consistently advocated for stronger legislative safeguards before widespread police adoption of this technology.
