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StopWatch's Response to Biometrics and Facial Recognition Technologies

Read StopWatch's full and detailed response to the Home Office consultation on a new legal framework for law enforcement use of biometrics, facial recognition and similar technologies

The history of police use of biometric technologies in the UK, particularly live and retrospective facial recognition, demonstrates the dangers of deploying highly intrusive surveillance tools without a clear statutory basis. Law enforcement agencies have repeatedly introduced biometric surveillance first and sought legal justification later, resulting in practices that civil society organisations, regulators, and oversight bodies have found to be disproportionate, opaque, and unlawful.

Evidence from live facial recognition deployments shows extremely low arrest and charge rates relative to the scale of surveillance, meaning vast numbers of people are subjected to biometric processing with little public safety benefit. For instance, StopWatch’s analysis of the Metropolitan Police’s live facial recognition (LFR) data of 79 LFR deployments made between 1 January and 30 June 2024 shows that nearly 500 hours of surveillance scanning almost 160,000 faces led to only 231 arrests. Met officers stopped a person on average once every 55 minutes. This led to an arrest every 128 minutes – the equivalent of 1.5% of all passers-by – but more often ended in no further action taken (every 95 minutes, or 308 engagements).

Police forces have repeatedly deployed LFR without a clear statutory basis, with weak internal governance, and with deeply concerning outcomes. Independent scrutiny has already found these deployments to be incompatible with Articles 8, 10 and 11 of the European Convention on Human Rights. Allowing police to self-authorise the use of such technologies, even in ‘exceptional’ cases, would simply entrench these failures.

For a full explanation of our position, please download and read our submission.

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