Context
The ICO has published an Outcomes report highlighting the key findings and shared themes from five consensual audits of police forces in England and Wales (including West Yorkshire and Greater Manchester) that are using overt facial recognition technology (FRT). It covers audits conducted between June 2025 and March 2026. The report aims to help all police forces identify potential areas for improvement in their use of FRT. This is accompanied by a blog by Emily Keaney, the ICO Deputy Commissioner for Regulatory Policy, in which she discusses balancing the risks and benefits of FRT and providing some headline detail about the main findings.
Key points to note and next actions
- The objective of the audits was to assess the extent to which the following are in place and operational for FRT within each force:
- Accountability.
- Policies and procedures.
- Performance measurement controls.
- Reporting mechanisms to monitor compliance.
- From the audit programme, the ICO noted several principal areas for improvement that featured in individual forces or across several of the participating police forces.
- The key audit findings are set out under the main themes identified, and each contains useful general commentary:
- Governance and accountability, including oversight, document control, and defined roles.
- Data mapping and records of processing.
- Training and awareness.
- Lawful bases.
- Data protection impact assessments (DPIAs).
- Data minimisation and limitation.
- Contracts and providers.
- Security management.
- Accuracy and bias.
- Individual rights.