To face match or not to match

Amidst growing concerns about the use of facial recognition technology (FRT), including live facial recognition (LFR), by police and private sector organisations, the Biometrics Institute has released a timely paper, Members’ Viewpoints: The Use of Facial Recognition in Policing.

Arising from the absence of a single law governing police use of LFR in the UK, this paper reflects viewpoints gathered by the Institute from its diverse membership regarding the use of LFR. An urgent need exists for a clearer, consistent framework governing FRT use in public places. Members argue that because public perception links police and private use of FRT, the standards and policies governing their use should be aligned. As the paper highlights “Private sector usage of facial recognition influences public perception. It should match the same standards and policies as police and law enforcement use, as citizens will see the two use cases in the same light.”

The paper also highlights the risk of rejecting FRT outright due to perceived risk, rather than strategically evaluating its potential benefits through robust policy and process development, as illustrated by the Institute’s Three Laws of Biometrics.

Public trust: The cornerstone of responsible FRT

Recognising the transformative potential of FRT, particularly LFR, and acknowledging its inherent risks, the Institute members emphasise the critical need for a balanced approach that prioritises public trust, individual rights, and societal well-being. Missteps in FRT deployment, both domestically and internationally, can erode this trust. The paper highlights members’ viewpoints on the crucial role of informed decision-making, clear communication, and transparency in the development and deployment of this technology. Institute members also note that police have always engaged in facial recognition, albeit through human observation, raising questions about how this compares to machine-assisted facial recognition in terms of accuracy and potential bias.

“Facial recognition technology presents both significant opportunities and complex challenges,” says Isabelle Moeller, CEO of the Biometrics Institute. “Its potential to enhance security, improve efficiency, and address societal issues is undeniable. However, it is crucial that the deployment of FRT and live facial recognition (LFR) is guided by a strong ethical framework, robust regulatory oversight, and a commitment to transparency and accountability.”

Effective use requires policy: Applying the Three Laws of Biometrics

The Institute’s Three Laws of Biometrics – Policy, Process, and Technology – provide a framework for responsible implementation of biometric systems. Public and private sector organisations considering the use of FRT should develop robust policies to guide its application, adhering to these Three Laws.

Responsible use of biometrics depends on informed decision-making, clear communication, and transparency. Therefore, operations involving FRT, including LFR, should be fully transparent and developed in accordance with the Institute’s Three Laws: Policy must always precede process and technology. Our members have raised the important question of whether private sector facial recognition deployments (e.g., in retail, clubs, and stadiums), which no doubt influence public perception, should adhere to the same standards and policies as law enforcement LFR. This is particularly relevant given the likelihood that citizens will see the use cases in the same light.

The Good Practice Framework also serves as a comprehensive risk management tool, guiding organisations through the strategic planning, procurement, and operation of biometric systems. This framework emphasises a holistic approach that carefully considers ethical, legal, and societal implications alongside technological considerations. It has been developed by Biometrics Institute members including experts and practitioners that bring together hundreds of years of experience with biometrics.

Transparency and accountability necessary to building confidence in FRT

Open and honest communication about how FRT is used, including transparent information on data collection, storage, usage, and safeguards, is crucial. FRT deployment must adhere to strong ethical principles, ensuring fairness, non-discrimination, and respect for human rights. Rigorous measures must be in place to address algorithmic bias and the potential for discrimination. Robust data protection measures are essential to safeguard individual privacy and prevent unauthorised access or misuse of biometric data. Data minimisation principles should be strictly adhered to, and data retention policies carefully considered. Independent oversight mechanisms, including regular audits and evaluations, are crucial to ensure accountability and address potential misuse of FRT systems.

Focus must extend beyond compliance

Global collaboration is crucial to establish common standards and best practices for FRT deployment. International cooperation can facilitate the exchange of knowledge, best practices, and regulatory frameworks.

Organisations using or planning to use facial recognition technologies should actively engage with the Biometrics Institute and leverage its expertise. This includes embracing independent testing and evaluation to ensure systems are fit for purpose and meet the highest standards of accuracy and fairness, including addressing potential demographic differentials. Members point out that as noted by the National Institute of Standards and Technology (NIST), top-performing algorithms exhibit minimal such differentials. By prioritising transparency, accountability, and continuous improvement, we can harness the potential of FRT to support law enforcement while upholding the fundamental rights and freedoms. The paper notes ‘Considering algorithm accuracy is necessary but not sufficient. There are many variables that must be considered…. With few exceptions, humans are far more error-prone, and exhibit far more real bias, than the best algorithms.’

The Biometrics Institute is committed to fostering a global dialogue on the responsible use of FRT. Through its engagement, education, and advocacy efforts, the Institute aims to empower stakeholders with the knowledge and tools necessary to navigate the complexities of FRT deployment and ensure that this powerful technology is used for the benefit of society.

For a deeper dive into the broader implications of facial recognition and LFR, readers are encouraged to participate in upcoming Institute events and to access the full paper, Members’ Viewpoints: The Use of Facial Recognition in Policing which is publicly available on the Biometrics Institute website. Further discussion on the use of FRT among Institute members will continue online at the On the Pulse: Facial Recognition in Public Places meeting on 3 April 2025.

ENDS

About the Biometrics Institute 

The Biometrics Institute is the independent and impartial international membership organisation for biometric users and other interested parties. It was established in 2001 to promote the responsible, ethical and effective use of biometrics and has offices in London and Sydney. 

The member register which represents a global and diverse multi-stakeholder community now lists over 200 membership organisations from 41 countries. It includes banks, airlines, government agencies, biometric experts, privacy experts, suppliers, academics and 18 Observers representing United Nations agencies, IGOs and European Union institution. 

The Biometrics Institute connects the global biometrics community. It shares knowledge with its members and key stakeholders and most importantly, develops good practices and thought leadership for the responsible, ethical and effective use of biometrics. 

For more information, please email Marco Lombardi.