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ICO steps up scrutiny of police use of facial recognition technology with audit of South Wales Police and Gwent Police

  • Date 20 August 2025
  • Type Blog

Few technologies are having as great an impact on modern policing as facial recognition technology (FRT). It can bring clear benefits in helping to prevent and detect crime, but it comes with real risks to people’s rights and freedoms – such as the potential for discrimination and misidentification – if not used responsibly. 

We have been clear that FRT does not operate in a legal vacuum. It is covered by data protection law, which requires any use of personal information - including images of people’s faces - to be lawful, fair and proportionate. As FRT is rolled out further, police forces must ensure the appropriate safeguards are in place.  

The ICO has a crucial role in scrutinising how FRT is used in practice, ensuring police forces are compliant with data protection law and that people’s rights are protected. Our recent AI and biometrics strategy reinforces our commitment to ensuring the proportionate and rights-respecting use of FRT by the police – which will in turn, improve public trust and confidence in the safeguards surrounding its use.  

As part of our strategy, we are conducting a series of audits of police forces who have been early adopters of FRT across England and Wales – securing firm assurances that deployments are properly governed and using people’s personal information lawfully.  

Today, we have published a summary of our first audit in the series which looks at South Wales Police and Gwent Police. These two forces use FRT in several ways, including live facial recognition (LFR), where cameras match images to a watchlist in real time, and retrospective use of FRT, where images captured are compared with a database. We also provided feedback on the pilot scheme of Operator Initiated Facial Recognition (OIFR), where an officer uses an authorised mobile device to compare an image to a database, helping to identify someone for policing purposes.   

The audit specifically assessed how the two forces govern their use of FRT and the protections they currently have in place to safeguard people’s personal information – such as staff training, retention of personal information and Data Protection Impact Assessments to mitigate risks. Our audits focus on governance and how personal information is used, rather than a detailed assessment of the technology.  

We are encouraged by the findings, which provide a high level of assurance that the processes and procedures currently in place at South Wales Police and Gwent Police are compliant with data protection law.  

The forces made sure there was human oversight from trained staff to mitigate the risk of discrimination and ensure no decisions are solely automated, and a formal application process to assess the necessity and proportionality before each LFR deployment. 

This audit serves as a snapshot in time, looking at the current use of FRT by two forces only. It does not give the green light to all police forces but those wishing to deploy FRT can learn from the areas of assurance and areas for improvement revealed by the audit summary.  

Audits are just one tool in our programme of work to ensure police forces are using FRT fairly and proportionately. We have been monitoring the use of FRT since it was first used by UK police in 2016, producing relevant guidance and an Opinion from the Commissioner 

As FRT is used more widely, we continue to engage with police forces on appropriate safeguards and set out clear expectations for its use. We will be auditing further forces – including the Metropolitan Police, Essex Police and Leicestershire Police - and publishing our findings in due course, as well as a detailed outcomes report once the series concludes.  

The use of FRT by the police is frequently in the spotlight, reflecting public concerns about the technology’s use and oversight - including its potential to be intrusive and the risk of both discrimination and mistaken identity. Our recent research found that while almost two-thirds of people surveyed (63%) felt comfortable with police using FRT, their support relies on the technology being accurate, unbiased and respecting of people’s privacy, as well as being used in a way that clearly benefits society.   

The value of FRT comes when it can be deployed in a way that both supports effective policing and attracts public support. Finding that balance is crucial, and we welcome work led by the Government to continue this debate, and what it means for the law.