FOI release

BSCC-FOI-0526-CB: information on non-law enforcement deployment of facial recognition and biometric surveillance technologies

Updated 27 July 2026

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

27 July 2026

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

To: [redacted]

Letter by email

Reference: BSCC-FOI-0526-CB

Thank you for your e-mail of 22nd July 2026, in which you ask for information on non-law enforcement deployment of facial recognition and biometric surveillance technologies. You requested information under the Freedom of Information Act 2000 (FOIA) and the Environmental Information Regulations 2004 (EIR).

Under section 12(1) of the FOIA, I am not obliged to comply with an information request where to do so would exceed the appropriate limit. As my office is an arms-length body of the Home Office, we estimate that the cost of locating and collating any relevant information and extracting the information to meet your request would exceed the appropriate limit of £450 specified in the Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulations 2004. We are therefore unable to comply with it. The £450 limit is based on work being carried out at a rate of £25 per hour, which equates to 18 hours of work per request. The cost of locating, retrieving and extracting information can be included in the costs for these purposes.  
 
This is because, in order to respond to your request for information, my team would need to search several email inboxes and around 6,000 files for information pertaining to all 37 of the points in your request. It is estimated that the time taken to identify whether we hold, search for, and collate any information falling within scope of your request would exceed the appropriate limit, therefore section 12 of the Act is engaged.  

With regard to your request under the Environmental Information Regulations 2004, Regulation 12(4)(b) permits a public authority to refuse a request where it is manifestly unreasonable. In this case, I consider the request to be manifestly unreasonable because of the disproportionate burden placed on the resources of the Office of the Biometrics and Surveillance Camera Commissioner. In order to disclose information under EIR, my office would need still need to carry out the searches detailed above as part of the FOI request but would additionally need to manually search all the documentation determine what information, if any, within it is environmental in nature. I have considered the public interest in disclosure and recognise that there is a public interest in transparency, accountability and public understanding in environmental matters. However, it is also in the public’s interest to ensure that the OBSCC’s limited resources are used effectively to carry out its statutory functions. Additionally, it is unlikely that my office holds information falling under EIR sought in the request as that does not sit within my oversight remit. Systematically manually searching through all the required documentation to comply with this request would require disproportionate use of my team’s time and resources. Having balanced the competing public interests, I consider that the public interest in maintaining the exception outweighs the public interest in disclosure in this case.

If you refine your request, for example, by limiting the number of topics covered by your request I may be able to comply with a future request. However, I cannot guarantee that this would be the case. 

I should also point out that if you submit a revised request it is possible that other exemptions in the Act might apply. 

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-0526-CB. If you ask for an internal review, it would be helpful if you could say why you are dissatisfied with the response.

[redacted]
5th 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

Professor William Webster
Biometrics and Surveillance Camera Commissioner

Email: enquiries@obscc.org.uk