Face Off

In the first Parliamentary debate on police use of live facial recognition technology, significant concerns were raised in relation to the latitude afforded to chief officers in deploying the biometric artificial intelligence (AI) tool. Handley Gill’s specialist consultants, whose advice on the deployment of LFR was acknowledged during the debate, consider the implications of the new Labour government’s proposals to revisit the legislative and regulatory framework governing the deployment of live facial recognition by law enforcement.

Now you see me...

As police forces are encouraged by the government to expand their use of live facial recognition technologies, with the Prime Minister announcing additional funding, Handley Gill Limited’s specialist consultants consider the legal issues that arise and the actions that Chief Constables and forces must take prior to deploying or even procuring LFR for law enforcement purposes.

Nicola Cain15 April 2024Data Protection, Personal Data, Part 3 DPA 2018, Part 3 Data Protection Act 2018, Law Enforcement, Law Enforcement Processing, Police, Policing, Biometric data, Biometric Processing, Sensitive Processing, Human Rights, DATA PROTECTION ACT 2018, Human Rights Act 1998, Article 8, Article 8 ECHR, Article 8 European Convention on Human Rights, Article 14 ECHR, Article 14 European Convention on Human Rights, Facial Recognition, Live Facial Recognition, LFR, Public Sector Equality Duty, PSED, Discrimination, Bias, Surveillance, Surveillance Camera Commissioner, Biometrics Commissioner, Data protection impact assessment, DPIA, Appropriate Policy Document, Equality Impact Assessment, Community Impact Assessment, Human Rights Impact Assessment, Cyber Security Risk Assessment, Integrated Impact Assessment, Model Card, Algorithmic Impact Assessment, Algorithmic Transparency Report, Algorithmic Transparency, Data Processing Agreement, Data Sharing Agreement, Joint Controller Agreement, Privacy Policy, Privacy Notice, House of Lords Justice & Home Affairs CommitteeComment

Barely recognisable?

Handley Gill Limited’s consultants respond to the Information Commissioner’s consultation on the draft Biometric Data Guidance Phase 1. We call for clarity on the circumstances in which the deployment of biometric recognition technologies will be considered to be lawful, particularly in the context of employment and the workplace, confirmation that a Data Protection Impact Assessment (DPIA) will always be required when deploying biometric recognition technologies and inclusion of the benefits and risks of biometric recognition. Finally, we argued for greater clarity about the requirements for further processing of special category biometric data.

Deep Impact on Data Protection Impact Assessments

Data controllers should revisit their Data Protection Impact Assessments (DPIAs).

DPIAsNicola Cain15 November 2020Data protection, Data protection impact assessment, GDPR, Article 35, Law enforcement processing, High risk processing, Data controller, Criminal conviction & offence data, Data Protection Act 2018, Section 64, Biometric data, Systematic public monitoring, Law Enforcement, Law Enforcement Processing, DPIA, Part 3 Data Protection Act 2018