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Published: 27 June 2025

Live Facial Recognition Report - 10 June 2025

Keywords : Live Facial Recognition

Report Summary

This report provides members of the Scottish Police Authority Policing Performance Committee with an overview of the work conducted as part of the Police Scotland, Scottish Police Authority and Scottish Biometrics Commissioner’s National Conversation on Live Facial Recognition.

To access the full document please open the PDF document above.

To view as accessible content please use the sections below. (Note that tables and some appendices are not available as accessible content). 

Meeting

The publication discussed was referenced in the meeting below

Policing Performance Committee - 10 June 2025

Date : 10 June 2025

Location : online


Findings from the National Conversation

Survey

Between 10 April to 4 May 2025, a public survey was hosted on both the Authority and Police Scotland’s website. The survey was published on social media, and it was also shared by a number of special interest groups amongst their networks. The survey builds on 2021 polling by the Scottish Biometrics Commissioner, which noted that 66% of the public were supportive of Police Scotland using technology in public spaces that can identify people’s faces to help find persons wanted by the Police. This increased to 72% in 2025.

There were 2,694 responses to the survey. It should be noted that while the sample is reasonably large given the time period applied, it cannot be considered as representative of the Scottish population. Findings are therefore indicative only.

Questions focused on levels of comfort with the use of LFR in routine policing; levels of comfort in usage by Police Scotland was only in certain circumstances; level of comfort with usage in each of the use cases; and level of agreement for Police Scotland carrying out further public engagement. Demographic questions were also included, following the same wording as the Your Police Survey.

Key headline findings were:

The survey showed the participants were almost perfectly divided in terms of comfort with our potential use of LFR. 49% were ‘very’ or ‘somewhat comfortable’ and 48% were ‘somewhat’ or ‘very uncomfortable’ with Police Scotland using LFR in the delivery of policing in Scotland.

The operational deployment of LFR e.g. for specific operations or as part of routine policing, did not affect levels of comfort significantly. Respondents were most likely to have no change in comfort if Police Scotland only used LFR in specific circumstances as opposed to it being part of routine policing in Scotland (48%).

30% of survey respondents said they would be more comfortable if Police Scotland used this technology in specific circumstances.

In relation to the three specific use cases, the majority of respondents were ‘very’ or ‘somewhat comfortable’ with Police Scotland using LFR. Levels of comfort in these specific scenarios were c.60%.

Overall, the majority of respondents felt Police Scotland should continue the conversation on the potential use of LFR in Scotland. (64%) ‘strongly agreed’ or ‘agreed’ with Police Scotland carrying out further public engagement on the use of LFR in Scotland.

There were mixed views in terms of generic use, but higher degrees of comfort with the use case scenarios.

While there were some variations by gender identity and age of respondents, it was not possible to disaggregate the data by other demographics (e.g. ethnicity, disability etc.) due to low sample sizes. Therefore, any future work on this topic would require targeted engagement to ensure a representative view of the Scottish public.

See Appendix A for further detail and survey analysis.

Focus Groups

In April 2025, five focus groups were hosted by Police Scotland, the Scottish Police Authority and the Scottish Biometrics Commissioner’s office. A broad range of organisations were invited, with a view to generating an inclusive and engaging conversation. In total, there were representatives present from 26 organisations (e.g. criminal justice, equalities, victims support services, academia, government bodies etc.). We also held individual discussions with some organisations who were unable to attend a focus group. This included one group which represented violence against women and girls.

The groups were chaired by Police Scotland and the Scottish Police Authority and it was made clear from the outset, that the purpose of the sessions was not for Police Scotland or any other tripartite participant to seek to express their views on the potential use of LFR, nor to seek to convince others, but instead that its focus was to listen to the views of those in attendance so that contributions could be considered in reaching any recommendation on how to proceed.

Conversations in the focus groups were both spirited and diverse in nature with a range of views, both in support and concern, expressed. Specifically, the conversation was framed around the following areas:

the potential impact on Scottish society of Police Scotland using LFR.


thoughts on the use cases outlined by Police Scotland.


potential safeguards or other ways in which human rights and ethical concerns might be mitigated.


views on Police Scotland further exploring the use of LFR; and the level of agreement for Police Scotland creating detailed proposals for the introduction of LFR for further public engagement followed by consideration by the Authority.

Notes taken during each focus group were analysed thematically, with four key themes being identified:

Assurance – There was significant discussion about transparency in LFR usage, governance and accountability of LFR usage, actual or perceived biases of the technology with regards to ethnicity, and the need for a clear purpose for using LFR.

Legislation – Several participants expressed their opinion that there was a need for primary legislation to govern the use of LFR. Discussions also focussed on the democratic basis for LFR, the unique statutory duty of Police Scotland around welfare, and other legislative/regulatory frameworks that could be supported or negatively impacted by LFR.

Deployment conditions - e.g. oversight of LFR use and monitoring/authorisation of deployments and assurance of performance, accuracy of the technology and how to manage bias and misidentification, demonstrable proportionality in deployments, lawfulness of deployment, transparency of deployment, and parameters of use i.e. guiding principles or a prescriptive use case list.

Support – there was mixed support for the continuing of the conversation and /or implementing LFR at some point in the future. There was no unqualified support for LFR from stakeholders, with further detail or assurances being desired prior to any support.

Written Submissions

Independent of the aforementioned engagement activities, some organisations provided additional written submissions for which we were grateful. The majority of these submissions provided further detail on why these organisations did not support the implementation of LFR by Police Scotland.

Key points included: a need for primary legislation; the impact of LFR on human rights; suggested incompatibility of LFR with the Public Sector Equality Duties; the potential for a ‘chilling effect’ in exercising rights to assembly and expression; concern around accuracy and bias of LFR technology for specific segments of the population (e.g. people from minority ethnic backgrounds or trans/non-binary individuals); suggestions of limited evidence of effectiveness in use elsewhere; and lack of detail on how LFR would be used (e.g. how watchlists are generated).

See Appendix C for further detail.

 


Related Publications

The documents below are related by Topic and are the most recently published

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HMICS Improvement Plans – Progress Summary - 10 June 2025

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Sex & Gender Review Update - 10 June 2025

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