Facial Recognition: how policing in Scotland makes use of this technology - Call for Evidence

The Scottish Parliament’s Justice Sub-Committee on Policing is undertaking an inquiry into how policing in Scotland makes use of facial recognition technology.

Please note that in most cases your written submission will be published on the Scottish Parliament’s website and may be quoted in the Committee’s report or in Committee meetings (which are in public and broadcasted).

If you wish to request that your submission be published without your name, please contact the clerks by emailing [email protected] or telephoning 0131 348 5220. 

Before making a submission, please read our privacy notice about submitting you views to a committee. This tells you about how we process your personal data. 

Please tell us if you are 12 or younger when making a submission. This is because we will need to ask your parent or guardian to confirm to us that they are happy for you to send us your views. Please read this privacy notice for children and young people before making your submission. 


Police Scotland’s 10-year strategy, Policing 2026, includes a proposal to introduce the use of facial recognition technology. Police Scotland recently wrote to the Sub-Committee indicating that facial recognition is part of the wider suite of current and developing biometric technologies that it has an ambition to explore. Police Scotland confirmed their intention to await the developments in the passage of the Scottish Biometrics Commissioner Bill, which the Justice Committee is currently scrutinising, before introducing the use of facial recognition software. 

Police Scotland also confirmed that they had not undertaken any trials of facial recognition technology in “a live setting through, for example, public space cameras, CCTV or other means, has not been trialled, tested or piloted in Police Scotland”. 

Police Scotland explained that they currently use retrospective facial technology, such as uploading images to the UK Police National Database (PND) which has a ‘facial search’ facility. 

The remit for the Sub-Committee’s inquiry is to consider how policing in Scotland makes use of facial recognition technology. The Sub-Committee will consider whether the use of that technology is lawful, ethical, proportionate and transparent.  

Areas of interest 

You are invited to submit written views to the Justice Sub-Committee on the above remit and the following areas: 

• The type of facial recognition technology used by the police service, the circumstances, and any implications. For example, Police Scotland accessing facial recognition images from CCTV cameras, national databases, body worn video cameras, and potentially mobile phones. 

• The circumstances in which equipment is used to capture images, for example the use of body worn video cameras at major events, such as protests and football matches. 

• The purpose of using facial recognition technology. For example, Police Scotland’s practice of sharing images with UK police forces through the use of the Police National Database (PND), which has a ‘facial search’ facility. 

• Any data protection, security and retention implications, and the equalities and human rights implications of the use of facial recognition technology (either by Police Scotland or by private sector entities on their behalf). 

• The legal and regulatory basis that Police Scotland rely upon to use facial recognition technology. 

• The oversight, governance and transparency of Police Scotland’s use of facial recognition technology. 

Please note that it is not necessary to cover every area and that you can also provide any other information that you consider to be relevant to the remit. 

It is important to point out that the Sub-Committee is seeking views on the use of facial recognition technology by Police Scotland. It recognises that for some their views of the police service and its use of this technology will be informed by their personal experiences. In responding to the call for views you may however wish to note that the Sub-Committee will not become involved in or investigate individual cases or specific complaints. In those circumstances you may wish to focus your written evidence on whether the police service’s use of facial recognition technology raises any policy concerns. 

Submitting evidence 

The deadline for sending written submissions is 5.00 pm on Friday 1 November 2019. Due to the time required to process and analyse evidence, late submissions will only be accepted with the agreement of the clerk. 

There are a few situations where we may choose not to publish your evidence or have to edit it before publication for legal reasons, including data protection and defamation. 

We welcome written views in English, Gaelic, Scots or any other language. Those submitting evidence are invited to restrict their submission, if possible, to the equivalent of approximately four sides of A4. Evidence should be submitted in electronic format (preferably in MS Word) by email to: [email protected]  

Organisations and individuals who do not have access to a PC and/or the internet may submit a hard copy submission to: 

Clerk to the Justice Sub-Committee on Policing 

The Scottish Parliament 


EH99 1SP

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