Report Summary
Issued 3 September 2025, this FOI response explains the first part of the request exceeds the cost of compliance and provides information to assist the requester. Information regarding private session transparency is provided.
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Request
Your request for information dated 13 August 2025 is copied below.
Thank you for your response to FOI request 2025/26-045 dated 7 August 2025. I appreciate the provision of public minutes, registers of interest, and recruitment documentation.
To support the integrity of this public-interest inquiry, I respectfully seek further clarification on the following:
- Oversight of Enforcement Infrastructure
- Does SPA maintain any internal governance documents, memoranda of understanding, or operational protocols relating to Police Scotland’s use of biometric systems, surveillance technologies, or enforcement platforms?
- Are any internal reviews, risk assessments, or ethical evaluations conducted prior to approving or funding such systems?
- Private Session Transparency and Redaction Protocols
- While private session minutes are withheld under Section 12, has SPA considered publishing redacted summaries or decision logs to support public transparency?
- Is there a formal redaction protocol or review process that could be applied to narrow the scope of disclosure?
- Jurisdictional Authority and Corporate Identity
- Does SPA hold a Legal Entity Identifier (LEI), D-U-N-S® number, or equivalent commercial registration?
- Under what legal framework does SPA operate—statutory corporation, executive agency, or incorporated governance body?
- Are individuals engaging with SPA or subject to its oversight presumed to be interacting with a public authority or a corporate governance entity?
On 18 August 2025 we requested clarification to assist in narrowing the scope of your request.
Your response received on 18 August is copied below.
Thank you for your response regarding my FOISA request. I’m happy to provide clarification to assist your business areas in progressing the request.
To confirm:
1. The phrase “Does SPA maintain…” is a request for recorded information. I am seeking copies of any governance documents, memoranda of understanding, or operational protocols held by SPA relating to Police Scotland’s use of biometric systems, surveillance technologies, or enforcement platforms.
2. The technologies of particular interest include:
- Live facial recognition (LFR)
- Body worn video (BWV)
- Remotely Piloted Aircraft Systems (RPAS/drones)
- Mobile biometric devices or platforms used for identity verification
3. By “enforcement platforms,” I refer to digital or technical systems used to support operational policing, including:
- Surveillance and biometric identification systems
- Predictive policing tools
- Data analytics platforms used for enforcement decision-making
- Any integrated systems used to coordinate or deploy enforcement resources
4. Please consider the timeframe for this request to be from 1 January 2023 to the present.
Regarding the second part of the request, I am seeking any internal reviews, risk assessments, or ethical evaluations conducted prior to SPA approving or funding the systems listed above. This includes:
- Ethical impact assessments
- Human rights or privacy impact reviews
- Risk registers or internal briefing notes
