Civil society: Police facial recognition should be strictly restricted
Police facial recognition use within the UK should be restricted to “strictly mandatory and proportionate” instances to guard folks’s collective and particular person rights, says civil society coalition.
Initially introduced by then-home secretary Yvette Cooper in July 2025, the UK authorities is about to determine a particular authorized framework for police facial recognition, which the King’s Speech in Could 2026 confirmed can be contained inside the upcoming Police Reform Invoice.
In line with the King’s Speech, the framework will clarify “when use of those applied sciences may be justified” and contains the “creation of a single, professional regulatory physique to offer impartial recommendation and oversight”.
Responding to the bulletins, 12 digital rights teams – together with Massive Brother Watch, Liberty, Justice, the Finish Violence In opposition to Girls Coalition and the Open Rights Group – have signed a joint assertion mapping out the “minimal, mandatory protections” wanted to make sure police facial recognition doesn’t trample over key human rights.
This contains protections towards each dwell facial recognition (LFR), which acts like a biometric checkpoint by scanning the faces of passers-by in actual time, and retrospective facial recognition (RFR), which is utilized by police to analyse recorded footage. Each are matched towards a watchlist to determine people of curiosity to the police.
The joint assertion outlined the “minimal, mandatory protections” wanted to guard human rights, and urged the Dwelling Workplace to ban using LFR apart from “strictly outlined policing functions”.
This contains the place there’s a menace to life, affordable grounds to consider the individual has dedicated a critical felony offence, and within the focused seek for lacking individuals and victims of kidnapping or trafficking.
The proposed framework goals to make sure that LFR and RFR are used for focused and justified causes, quite than as an on a regular basis policing instrument, to guard the general public’s freedom to privateness and expression.
“They characterize the minimal normal the invoice should meet with the intention to present a transparent, coherent and sustainable framework for facial recognition that mirrors our democratic counterparts [in Europe], while providing some safety to most people from extreme AI surveillance,” wrote the teams.
LFR vs RFR necessities
On LFR deployments, the coalition really useful requiring detailed justifications by legislation enforcement our bodies, together with that the “particular person sought individual on the watchlist might be current on the proposed deployment location”, and that police ought to have exhausted all different measures of finding the individual in query.
LFR can also be really useful not for use in locations with “higher expectations of privateness”, resembling faculties, locations of worship, well being centres, polling stations or protests, to guard privateness and freedoms of expression.
Every deployment also needs to be authorised by a judicial or impartial administrative authority to make sure its use is simply.
If pressing deployment is important, documentation is additional required to justify its use in proportion to “human rights interference” – together with with a human rights affect evaluation, geographical relevance, if much less intrusive strategies have been exhausted, and its affect on weak teams.
Documentation, resembling human rights affect assessments, would additionally must be accomplished by the deploying legislation enforcement physique and submitted to an authorising physique.
The suggestions for RFR are much like these for LFR, the place the sought individual should solely be matched to photographs obtained lawfully, which might be updated, to forestall wrongful identification – this doesn’t embody composite photographs resembling police sketches.
Because it stands, nonetheless, the Dwelling Workplace continues to carry tens of millions of custody photographs unlawfully.
With RFR, the teams have referred to as for police to be prohibited from utilizing picture references taken from databases created by way of the untargeted scraping of facial photographs, or databases that embody people who find themselves not beneath investigation, with out felony convictions, or these comprised of non-police photographs.
Each LFR and RFR suggestions embody a requirement to publish outcomes of their deployments – such because the variety of makes use of, outcomes of matches, if it resulted in arrests, convictions or wrongful identification, and demographic information.
The teams additionally envisage the institution of an impartial oversight physique, which is empowered to conduct put up facto critiques of each particular person LFR deployments and their systemic use, set scientific validation necessities round accuracy and reliability, set varied requirements round design and efficiency, and conduct in-depth audits of police programs.
Because it stands, the know-how’s use just isn’t regulated by any particular regulatory framework and as a substitute operates by way of a “patchwork” of different legal guidelines, together with information safety guidelines and customary legislation policing powers.
In December 2025, the Dwelling Workplace launched a 10-week session on a authorized framework.
Whereas it’s but to formally reply to the session, the method aimed to assemble views on establishing a framework, resembling whether or not the know-how must be designed to entry and match facial imagery from different present databases – together with passport and driving licence photographs, custody data, and immigration information.
Past LFR, public opinion was consulted on different “biometric and inferential applied sciences”, resembling emotion detection to determine felony or self-harm behaviour, voice and gait recognition.
On the time of the session’s announcement, the Dwelling Workplace described the present guidelines in place for LFR as “sophisticated and obscure”, with Cooper including that the brand new framework was mandatory to provide police forces the “confidence to make use of it with the correct requirements in place”.
Regardless of this, and earlier than the session had even closed, the Dwelling Workplace introduced sweeping reform to UK policing in January 2026, which included vital funding within the LFR capabilities of police in England and Wales.
Earlier authorized problem
The transfer for “vital reforms to the police” outlined within the King’s Speech got here after a landmark authorized problem towards the Metropolitan Police’s use of LFR was dismissed by the UK Excessive Court docket on 21 April 2026, the place it was dominated that “the [Met’s LFR] Coverage incorporates enough and lawful constraints”.
Met commissioner Mark Rowley responded to the ruling, saying that the judgment confirmed that the Met was “deploying this know-how responsibly and with care”.
Introduced ahead by Massive Brother Watch’s director Silkie Carlo and anti-knife campaigner Shaun Thompson, who was incorrectly recognized by LFR know-how and described LFR as “cease and search on steroids”.
The authorized problem cited issues with discrimination and the disproportionate use of LFR in areas with giant ethnic minority teams, in addition to points across the permissiveness of the Met’s deployment standards.
Discriminatory algorithms
Accuracy and bias dangers have been present in Essex Police’s use of LFR in March 2026, resulting in the know-how’s suspension by the pressure. Laptop Weekly completely reported in 2025 that Essex Police had failed to think about the know-how’s potential discriminatory affect.
As a result of LFR software program generates a similarity rating when a match is recognized, which triggers an alert at a set threshold, legislation agency TSABI argued in a June 2026 weblog put up that if this threshold is about too low, “particularly in crowded or poorly lit public order eventualities the place the software program is almost certainly to make errors”, it dangers resulting in wrongful identification. TSABI added that sure algorithms carry out much less precisely on Black and Asian faces.
Equally, a Cambridge examine from March 2026 discovered that the know-how accurately recognized males over ladies and Black members over different ethnic teams.
Regardless of its reported bias and lack of regulatory frameworks, the federal government is pushing forward to roll out LFR know-how.
At the moment, 13 of 43 police forces throughout the UK have deployed LFR know-how, with Statewatch reporting that 4 further regional police forces throughout England used the know-how for the primary time previously six months.

