FOI release

BSCC-FOI-1225-HD: communications related to use of live facial recognition

Updated 12 September 2025

Office of the Biometrics and Surveillance Camera Commissioner
2 Marsham Street
London
SW1P 4DF

11 September 2025

https://www.gov.uk/government/organisations/ biometrics-and-surveillance-camera-commissioner

To: [redacted]

Letter by email

Dear [redacted]

I write in response to an email received by our office on Friday 15th August 2025 in which you asked:

“Please accept this request under the Freedom of Information Act for documents relating to the Commissioner’s oversight function with regards police use of live facial recognition technology. I’m seeking copies of the following records from the period 1 Jan 2022 to 31 Aug 2025:

1. Communications or guidance: Any letters, emails, or official communications from the BSCC to police forces or the NPCC regarding the proper use of live facial recognition. For example, advice about watchlist composition, accuracy/confidence thresholds, or compliance with the Surveillance Camera Code of Practice when using LFR at events or in public spaces.

2. Oversight reports or minutes: Any reports, meeting minutes, or briefing papers that discuss police live facial recognition trials or operations.

3. Accuracy/bias evaluations: Any summaries or data held by BSCC on the accuracy or error rates of LFR systems used by police (for instance, false match rates, or notes on demographic performance if evaluated). If detailed technical reports are held, I am happy to receive just executive summaries or conclusions.”

Your request has been handled as a request for information under the Freedom of Information Act 2000.

While the government has recently appointed an interim Biometrics Commissioner and is actively recruiting a permanent Biometrics and Surveillance Camera Commissioner through open competition, only the Surveillance Camera Commissioner is a relevant public authority under the Act. Therefore, this response has been provided by the Office, rather than the Biometrics Commissioner.

Please see copies of all records pertaining to your request held by this office, which are annexed to this letter. Attachments linked to the communications below have been provided separately. Please note that, where redactions have been made, they are made under section 40(2) relating to personal information. It is the policy of the Home Office to withhold the names of officials below the level of Senior Civil Servant and, as an arms-length body of the Home Office, OBSCC also follows this policy. We can confirm that the redactions relate to names and email addresses that would confirm the identity of the individual, or where additional opensource research could provide the identity of the individual (for example, where a person’s position or role is disclosed). Some material not falling within the scope of this FoI request has also been redacted; those sections are clearly marked.

If you are dissatisfied with this response, you may request an independent internal review of our handling of your request by submitting a complaint within two months to the address below, quoting reference BSCC-FOI-1225-HD. If you ask for an internal review, it would be helpful if you could say why you are dissatisfied with the response.

[redacted]
5 th Floor, 2 Ruskin Square
Broad Green
Croydon
CR0 2WF

e-mail: Sciencesupportfoi@homeoffice.gov.uk

As part of any internal review, our handling of your information request will be reassessed by staff who were not involved in providing you with this response. If you remain dissatisfied after this internal review, you have a right of complaint to the Information Commissioner as established by section 50 of the Freedom of Information Act.

Kind regards

Office of the Biometrics and Surveillance Camera Commissioner

Email: enquiries@obscc.org.uk

Annex of information held

Email 1

From: Enquiries

Sent: 24 March 2022 13:49

To: Enquiries enquiries@obscc.org.uk

BCC: [redacted S40]@met.police.uk’; [redacted S40]@south-wales.pnn.police.uk>;[redacted S40]@south-wales.police.uk’; [redacted S40]@south-wales.police.uk’; [redacted S40]@cpni.gov.uk>; [redacted S40]@west-midlands.pnn.police.uk>; [redacted – does not fall in scope of request; [redacted S40]@herts.pnn.police.uk>; [redacted S40]@herts.pnn.police.uk’; [redacted S40]@met.police.uk’; [redacted S40]@met.police.uk’; >; [redacted – does not fall in scope of request]

Subject: The lawful, ethical and acceptable use of facial recognition technology

Dear all,

Live facial recognition is the surveillance question that won’t go away whether it’s in our streets or our schools. I was therefore pleased to see the publication of the College of Policing Authorised Professional Practice on Live Facial Recognition which sets out a commitment to ‘lawful and ethical’ use of this technology. Being guided by lawful and ethical considerations will be critical in addressing people’s fears of state-owned surveillance companies supplying our police and schools with the facial recognition technology they’re using to perpetuate human rights atrocities against Uyghur Muslims in the Xinjiang region of China.

I do however have some concerns about the apparent intention to use live facial recognition technology to find potential witnesses. A witness is generally someone who has indicated their willingness to take part in the criminal justice process - in which case you don’t need a camera to identify them for you; you already know who they are. If we’re talking about tracking and compelling people to disclose what they heard and saw at a certain time just because they happened to be present, that’s a wholly different and pretty sinister development, and would call the legitimacy and proportionality of its use into question.

The overall direction in surveillance, coupled with the acute public sensitivity to some technology makes it all the more important to have independent oversight and regulation rather than treating this purely a matter for ‘data rights’.

I am keen to continue open, informed dialogue with stakeholders who have an interest in this area, from the avid supporters to the anti-surveillance campaigners and everyone in between. The proper role of technology in surveillance calls for balance, not only of what’s possible against what’s lawful, but increasingly alongside what we find acceptable. Societal acceptability is the ground where the accountable, ethical and legitimate use of surveillance technology is being shaped.

To achieve a greater understanding of the societal acceptability of facial recognition technology by law enforcement and others, my office is planning to put ‘Facial Recognition on Trial’. In conjunction with Professor William Webster (Centre for Research into Information, Surveillance and Privacy) the event will contribute to a key objective under the Civil Engagement strand of the National Surveillance Camera Strategy. The event will take place before a live audience and will imitate a court trial with evidence provided by expert witnesses and members of the public acting as a jury. The mock trial will be held on 14 June at the London School of Economics with tickets available to book soon. My website will continue to be updated as further details emerge.

Sincerely

Fraser Sampson

Professor Fraser Sampson

Biometrics and Surveillance Camera Commissioner

Please note I cover the statutory functions of both the Biometrics Commissioner and the Surveillance Camera Commissioner as outlined in the Protection of Freedoms Act 2012 Section 20 and 34, respectively.

Email 2

From: Enquiries

Sent: 05 April 2022 11:36

To: Enquiries enquiries@obscc.org.uk

BCC: [redacted S40]@south-wales.pnn.police.uk; [redacted S40]@south-wales.police.uk; [redacted S40]@bedfordshire.pnn.police.uk; [redacted S40]@herts.pnn.police.uk>; [redacted S40]@herts.pnn.police.uk; [redacted S40]@met.police.uk; [redacted S40]@met.police.uk; [redacted S40]@westyorkshire-pcc.gov.uk; [redacted S40]@westmercia.pnn.police.uk>;[redacted S40]@westyorkshire.pcc.pnn.gov.uk; [redacted S40]@westyorkshire.pcc.pnn.gov.uk; [redacted – does not fall in scope of request; [redacted S40]@met.police.uk; [redacted S40]@avonandsomerset.police.uk;

Subject: Response to CoP APP on LFR

Dear Colleagues,

For your interest, the Commissioner has produced an initial response to the College of Policing APP on Live Facial Recognition. This will be on our website in due course but do share with colleagues in the meantime.

Kind Regards,

Office of the Biometrics and Surveillance Camera Commissioner

Email 2 attachment annexed separately

Email 3

From: Enquiries

Sent: 12 April 2022 14:48

To: Enquiries enquiries@obscc.org.uk BCC: [redacted S40]@avonandsomerset.police.uk; [redacted S40]@bedfordshire.pnn.police.uk; [redacted S40]@bedfordshire.pnn.police.uk; [redacted S40]@cheshire.pnn.police.uk; [redacted S40]@cityoflondon.pnn.police.uk; [redacted S40]@cleveland.pnn.police.uk; [redacted S40]@cumbria.police.uk; [redacted S40]@devonandcornwall.pnn.police.uk>; [redacted S40]@dorset.pnn.police.uk; [redacted S40]@durham.pnn.police.uk; [redacted S40]@Dyfed-Powys.pnn.police.uk; [redacted S40]@essex.pnn.police.uk; [redacted S40]@gloucestershire.pnn.police.uk; [redacted S40]@gwent.pnn.police.uk; [redacted S40]@gwent.pnn.police.uk; [redacted S40]@hampshire.pnn.police.uk; [redacted S40]@humberside.pnn.police.uk; [redacted S40]@kent.pnn.police.uk; [redacted S40]@leicestershire.pnn.police.uk; [redacted S40]@lincs.pnn.police.uk; [redacted S40]@Merseyside.pnn.police.uk; [redacted S40]@norfolk.pnn.police.uk; [redacted S40]@northants.pnn.police.uk; [redacted S40]@northumbria.pnn.police.uk; [redacted S40]@northyorkshire.police.uk; [redacted S40]@nthwales.pnn.police.uk; [redacted S40]@nottinghamshire.pnn.police.uk; [redacted S40]@southyorks.pnn.police.uk; [redacted S40]@staffordshire.pnn.police.uk; [redacted S40]@suffolk.pnn.police.uk; [redacted S40]@surrey.pnn.police.uk; [redacted S40]@sussex.pnn.police.uk; [redacted S40]@thamesvalley.pnn.police.uk; [redacted S40]@westmercia.pnn.police.uk; [redacted S40]@west-midlands.pnn.police.uk; [redacted S40]@westyorkshire.pnn.police.uk; [redacted S40]@btp.pnn.police.uk; [redacted S40]@cnc.pnn.police.uk; [redacted S40]@psni.pnn.police.uk; [redacted S40]@herts.pnn.police.uk>; [redacted S40]@herts.pnn.police.uk; [redacted S40]@met.police.uk; [redacted S40]@met.police.uk;

Subject: Police Facial Recognition on Trial event LSE 14 June 2022

Good Afternoon,

As you may already be aware, the Biometrics and Surveillance Camera Commissioner has organised for Police facial recognition to be put on trial at a live event in June. Attached is the poster for more information. Further communication will be sent in the coming weeks regarding timings and ticket links, but in the meantime, you can register your interest by emailing the team on enquiries@obscc.org.uk.

Please do share with colleagues and other interested parties.

Kind Regards,

Office of the Biometrics and Surveillance Camera Commissioner

Email 3 attachment annexed separately

Email 4

From: Enquiries enquiries@obscc.org.uk

Sent: 20 April 2022 11:04

To: [redacted S40]@avonandsomerset.police.uk; [redacted S40]@avonandsomerset.police.uk Cc: [redacted S40]@avonandsomerset.police.uk>; [redacted S40]@avonandsomerset.police.uk

Subject: Recommendations from Biometrics and Surveillance Camera Commissioner following PoFA visit 30 March 2022

Good Morning Sarah,

Thanks once again to you and the Avon & Somerset team for accommodating our visit last Month. Please find attached a letter of recommendations following the visit.

Any questions or the desire for a follow up conversation please don’t hesitate to get in touch. Our office are always around to support you with the recommendations. Kind Regards,

[redacted S40]

Office of the Biometrics and Surveillance Camera Commissioner

Email 4 attachment annexed separately

Email 5

From: Enquiries enquiries@obscc.org.uk

Sent: 24 June 2022 09:54

To: Enquiries enquiries@obscc.org.uk

BCC: [redacted S40]@cheshire.police.uk; [redacted S40]@btp.police.uk>; [redacted S40]@cnc.pnn.police.uk>; [redacted S40]@cleveland.police.uk; [redacted S40]@essex.police.uk>; [redacted S40]@dyfed-powys.police.uk; [redacted S40]@devonandcornwall.pnn.police.uk; [redacted S40]@gloucestershire.pnn.police.uk; [redacted S40]@gmp.police.uk; [redacted S40]@gmp.police.uk; [redacted S40]@gwent.police.uk; [redacted S40]@hampshire.police.uk; [redacted S40]@kent.police.uk>; [redacted S40]@lancashire.police.uk; [redacted S40]@leicestershire.pnn.police.uk; [redacted S40]@lincs.police.uk; [redacted S40]@merseyside.police.uk; <[redacted S40]@norfolk.police.uk>; [redacted S40]@northants.police.uk; [redacted S40]@northumbria.police.uk; [redacted S40]@nthwales.police.uk; [redacted S40]@northyorkshire.police.uk; [redacted S40]@nottinghamshire.police.uk; [redacted S40]@south-wales.police.uk; [redacted S40]@southyorks.pnn.police.uk; [redacted S40]@staffordshire.pnn.police.uk; [redacted S40]@suffolk.police.uk; [redacted S40]@thamesvalley.pnn.police.uk; [redacted S40]@westmidlands.police.uk; [redacted S40]@wiltshire.police.uk; [redacted S40]@warwickshire.police.uk; [redacted S40]@warwickshire.police.uk; [redacted S40]@notts.police.uk; [redacted S40]@dorset.pnn.police.uk

Subject: Police Survey and Covering Letter from the Biometrics and Surveillance Camera Commissioner June 2022

Good morning,

For the attention of Chief Constables, please find enclosed a letter and survey from the Biometrics and Surveillance Camera Commissioner enclosed.

Could you please send your responses back to this email address by 26 August 2022.

Kind regards,

Office of the Biometrics and Surveillance Camera Commissioner

Email 5 attachment annexed separately

Email 6

From: Enquiries enquiries@obscc.org.uk

Sent: 29 September 2022 10:56

To: [redacted S40]@met.police.uk

Subject: Tech Monitor

Good morning, Please find below the TechMonitor article link from Commissioner regarding live facial recognition, which he has requested to be sent to you.

Facial recognition needs a stronger case in law enforcement - Tech Monitor

Kind regards

[redacted S40]

Office of the Biometrics and Surveillance Camera Commissioner

Email 7

From: Enquiries enquiries@obscc.org.uk

Sent: 11 October 2022 09:24

To: [redacted S40]@south-wales.police.uk

Cc: [redacted S40]@south-wales.police.uk; [redacted S40]@south-wales.police.uk

Subject: RE: Meeting with the Commissioner regarding SWP and the 2022 Police Survey

Hi [redacted S40],

Many thanks for your email and sorry to hear you do not recall receiving the survey. I have attached the survey and covering letter.

We have finished accepting submissions now however the Commissioner is still keen to catchup when you are next available to.

Kind regards,

[redacted S40]

From: [redacted S40]@south-wales.police.uk

Sent: 10 October 2022 20:28

To: Enquiries

Cc: [redacted S40]@south-wales.police.uk; [redacted S40]@south-wales.police.uk

Subject: RE: Meeting with the Commissioner regarding SWP and the 2022 Police Survey

Good evening,

Regarding below, can you confirm the actual original email please.

I can recall receiving something similar which did not involve the PNC Bureau but did involve other areas of the business (I believe custody services may have been one) and I forwarded it to those relevant departments.

However, I have no record of the original or my forwards for June this year which is rather concerning as I keep most emails for min of 6 months.

[redacted – not in scope of request submitted]

[redacted S40]

From: Enquiries

Sent: 10 October 2022 16:27

To: [redacted S40]@south-wales.police.uk; [redacted S40]@south-wales.police.uk; [redacted S40]@south-wales.police.uk

Subject: Meeting with the Commissioner regarding SWP and the 2022 Police Survey

Good afternoon,

I hope you’re all doing well. I am emailing on behalf of Fraser regarding the 2022 Police Survey we sent out in June this year.

We did not receive a submission from South Wales Police, so the Commissioner would like a catchup to discuss this and certain things that were within the survey.

Could you please provide me with some dates over the next week or so when you would be free.

Thanks in advance and kind regards,

[redacted S40]

Office of the Biometrics and Surveillance Camera Commissioner

[redacted S40]

Attachments same as email 5

Email 8

From: Enquiries enquiries@obscc.org.uk

Sent: 28 October 2022 15:27

To: [redacted S40]@westyorkshire.police.uk

Cc: Fraser Sampson Fraser.Sampson@obscc.org.uk

Subject: Meeting with the BSCC 28 October

Dear [redacted S40],

Fraser has asked to share the attached with you following your meeting with him earlier today.

In addition, he asked me to share his recent article with Tech Monitor.

Kind regards,

[redacted S40]

Office of the Biometrics and Surveillance Camera Commissioner

[redacted S40]

Email 8 attachment annexed separately

Email 9

From: Enquiries enquiries@obscc.org.uk

Sent: 23 June 2023 12:52

To: Enquiries enquiries@obscc.org.uk

BCC: [redacted S40]@herts.pnn.police.uk; [redacted S40]@met.police.uk; [redacted S40]@beds.police.uk; [redacted S40]@westyorkshire-pcc.gov.uk; [redacted S40]@met.police.uk; [redacted S40]@south-wales.pnn.police.uk>; [redacted S40]@south-wales.police.uk;

Subject: BBC Panorama - Is China Watching You? - 26 June 2023

Good afternoon,

The Commissioner would like to make you aware that he was interviewed by the BBC for their Panorama episode ‘Is China Watching You?’.

This will be aired at 8pm on Monday 26 June. The link to the programme is here.

Kind regards,

[redacted S40]

Office of the Biometrics and Surveillance Camera Commissioner

[redacted S40]

Email 10

From: [redacted S40]

Sent: Wednesday, July 5, 2023 3:57 PM

To: [redacted S40]; Fraser Sampson Cc: Enquiries ; [redacted S40]@met.police.uk; [redacted S40]@northants.police.uk; [redacted S40]@met.police.uk; [redacted S40]@south-wales.police.uk

Subject: RE: LFR Mutual Aid Silverstone F1 - Op.Pitlane

Hi [redacted S40]

Thanks for this. I’m curious to understand what is meant by engagement, particularly in terms of engagement with Fraser because, as I understand it, this is the first he or we (his office) are aware of this deployment.

And on the wider comms strategy, interested to see what that involves if possible (please do point me to a website if it’s published there).

If you could provide a bit more detail on that, it would be much appreciated

Thanks

[redacted S40]

Office of the Biometrics and Surveillance Camera Commissioner

From: [redacted S40]@south-wales.police.uk

Sent: 05 July 2023 15:37

To: Fraser Sampson Fraser.Sampson@obscc.org.uk

Cc: Enquiries enquiries@obscc.org.uk; [redacted S40]@homeoffice.gov.uk>; [redacted S40]@met.police.uk; [redacted S40]@northants.police.uk>; [redacted S40]@met.police.uk>; [redacted S40]@south-wales.police.uk>

Subject: RE: LFR Mutual Aid Silverstone F1 - Op.Pitlane

Do you trust this email? This email originated from outside the Home Office, or came from a Home Office system that has not been certified. Please exercise caution before opening attachments or clicking on links within this email or any suspicious email, particularly from unknown senders.

Hi Fraser,

The roundtable event is titled ‘ Industry roundtable on Facial Recognition (FR)’ which has been organised by the Policing Minster, this is scheduled for tomorrow with exact timings still to be confirmed.

I haven’t received a detailed agenda at this stage, the title would suggest the focus will be on our commercial partners but would expect the broader policing use of FRT to be a topic of conversation.

Northamptonshire Police are responsible for the LFR Comms Strategy which is due to be published tomorrow.

As you will be aware in terms of mutual aid it is an agreed principle that those officers come under the direction and control of the host Chief Constable (who is scrutinised by the host PCC).

That being said, South Wales Police have been clear that we needed to be satisfied that the deployment is in accordance with existing legislative requirements; CoP LFR APP, SC Code, Bridges, etc.

Northants Police have developed a robust FRT policy and governance framework which is being led by [redacted S40], this will include a post deployment review. SWP will be involved in this process which will include the opportunity to take learning directly back into the SWP FRT Board.

The board I mentioned in the original email is the NPCC FRT Board, this is chaired by Lindsey Chiswick (NPCC FRT lead) and includes police representation from across the UK.

There will of course be other opportunities for local and national learning and scrutiny. I hope I have answered some of the questions, please feel free to get back to me if you require anything further at this stage.

Thanks,

[redacted S40]

From: Fraser Sampson Fraser.Sampson@obscc.org.uk

Sent: Wednesday, July 5, 2023 2:50 PM

To: [redacted S40]@south-wales.police.uk>

Cc: Enquiries enquiries@obscc.org.uk; [redacted S40]@homeoffice.gov.uk>

Subject: RE: LFR Mutual Aid Silverstone F1 - Op.Pitlane

Hello [redacted S40]

Many thanks for sight of this. As you might imagine I have a few questions and have asked the team to take a look at it.

While I met with the Policing Minister last week I’ve not been advised of a roundtable event.

Our immediate considerations would be around the extent to which this is being publicised, the assurances around compliance with the SC Code and the arrangements for post-deployment review. Is the SWP FRT Board 19/7 a public meeting? Perhaps these are all on SWP website?

I hope you will be in the eponymous pitlane and get to see the event close up!

Kind regards

Fraser

From: [redacted S40]@south-wales.police.uk>

Sent: 05 July 2023 14:20

To: Fraser Sampson Fraser.Sampson@obscc.org.uk

Cc: Enquiries enquiries@obscc.org.uk

Subject: LFR Mutual Aid Silverstone F1 - Op.Pitlane

Do you trust this email? This email originated from outside the Inquiry, or came from a system that has not been certified. Please exercise caution before opening attachments or clicking on links within this email or any suspicious email, particularly from unknown senders.

Good afternoon Fraser,

I trust that you are well.

In advance of the Ministerial roundtable and more generally regards your role I thought it would be useful to ensure you were sighted on a request to SWP from Northants Police for LFR to be provided on a mutual aid basis at the F1 this weekend.

The request for mutual aid was authorised by the SWP FRT SRO on Tuesday 6th July 2023.

I have detailed a summary below for information.

1. Overview of deployment request

• This will be the first occasion LFR has been used on a mutual aid basis and will be the largest policing deployment of LFR outside of the UCL in Cardiff in 2017.
• Five deployment locations at the points of entry at the Silverstone Circuit – three vans and two static points (4th LFR van will act as resilience vehicle).
• Deployment on Sat 8th and Sun 9th July – 0700 – 1600 hrs
• Twelve trained LFR operators from SWP).
• Three NBF officers.
• SWP vehicle assets will display generic policing and LFR livery.
• Northants Police have adopted (where possible) SWP LFR documents – live on Northants Police website 5th July 2023.

2. SWP FRT SRO Review

• Robust review of Northants formal application.
• Hierarchical approach regards HR considerations.
• The application details the use of LFR in support of the overt policing tactics intended to safeguard vulnerable and missing people, prevent, disrupt and detect serious and/or organised crime and acts that are likely to cause loss of life or serious injury.
• Article 11 HRA considerations - Northamptonshire Police will not use LFR for the purposes of identifying individuals associated only with protest activity or only with low level criminality associated with protest activity.
• Eight deployment terms agreed by Northants which will be kept under review.
  • Northants will be the SRO and authorising officer and have legal liability for any claims and will indemnify SWP for any claims made against SWP as a result of the deployment.

3. Legal Review

• Legal counsel has been provided by [redacted] who is satisfied with Northants LFR application.

4. Communications Strategy

• SWP representatives have reviewed the Op. Pitlane Comms Plan in which LFR features.
• LFR Comms lines provided - consistent with what SWP have used previously.
• LFR Comms will not feature in support of any event contingencies.
• Comms to go live Thursday 6th July 2023.

5. Engagement

• Lindsey Chiswick, NPCC FRT lead – sighted.
• Rt Hon Chris Philp MP – sighted of the request.
• SWP PCC’s Office - sighted
• PCC Daryl Preston, APCC.
• Professor Paul Taylor, Police Chief Scientific Advisor.
• Professor Fraser Sampson, Surveillance and Biometrics Commissioner.

6. Learning

• Deployment summary to be detailed at NPCC FRT Board Wed 19th July 2023.
• Regionalisation/mutual aid of LFR to be specific agenda item.

If there any further questions at this stage please let me know.

Thanks,

[redacted]

Email 11

From: Enquiries Sent: 25 March 2024 15:59

To: [redacted S40]@met.police.uk

Cc: Enquiries enquiries@obscc.org.uk

Subject: BSCC visit to Croydon LFR- May

Good afternoon Lindsey,

I hope you are well.

The Biometrics and Surveillance Camera Commissioner would like to organise a visit to see the MPS efforts in Croydon regarding Live Facial Recognition in May.

Specifically, he would like to understand 1) the policy and strategy you are pursuing, and how you have decided upon it 2) what mechanisms you have in place with your suppliers regarding service standards - and how you test them 3) performance data and accountability, internally and externally with communities 4) briefings and training to frontline operators 5) how any complaints are managed, and 6) understanding ‘what’s next’ as the tech develops.

I’d be grateful if you could let me know a convenient date we could arrange a visit to see the operation in action. Any date between May 13th and 23rd, excluding the 14th, would be suitable for us.

I look forward to hearing from you.

Kind regards,

[redacted S40]

END

Office of the Biometrics and Surveillance Camera Commissioner