Policy paper

Commissioner's response to the Independent Review of Police Force Structures’ call for evidence (accessible)

Published 25 June 2026

I am grateful to have been extended the invitation, as the Biometrics and Surveillance Camera Commissioner (BSCC), to provide a response to the Independent Review of Police Force Structures’ call for evidence.

The roles of Commissioner for the Retention and Use of Biometric Material and Surveillance Camera Commissioner are independent appointments each made by the Home Secretary under the respective provisions of the Protection of Freedoms Act 2012. I provide independent oversight of how police forces retain and use DNA and fingerprints, and their compliance with the Home Secretary’s Surveillance Camera Code of Practice. And while not currently within my statutory remit, I am increasingly required to provide a position on new biometric technologies forces are considering deploying. The geographical extent of the role is England and Wales, and extends to Scotland and Northern Ireland for biometrics issues relating to national security matters.

The From local to national: a new model for policing white paper of January 2026 proposes structural change to the provision of policing in the UK, including a reduction in the number of police forces and the centralisation of certain functions. And, with a more direct impact on my role, it also proposes a new legislative framework to oversee the use by law enforcement of biometric technologies, from which stemmed the public consultation by the Home Office, which closed in February 2026^{[footnote 1]}. In my response to the consultation, which I have published on my website^{[footnote 2]}, I welcome the proposals to provide a clear, lawful basis for police use of facial recognition technology, and call for robust, meaningful oversight of its use, and that of other new and emerging biometric technologies. The consultation also proposes merging my office and that of the Forensic Science Regulator, to provide centralised regulatory oversight for biometrics, surveillance cameras and forensic science for all police forces. 

In my view, the key points arising from these proposed oversight changes, and their interaction with the police reform proposals are:

• I have reinstated the programme of visits to police forces undertaken by my predecessors to review and audit practices around DNA and fingerprint retention, use and destruction, and adherence to the Surveillance Camera Code of Practice. These visits were paused in 2022 ahead of the then impending closure of the office, which would have been brought about by the Data Protection and Digital Information Bill, which ultimately fell when a General Election was called in July 2024. It is and has always been an impossible task to attempt to visit all 43 territorial police forces in England and Wales every year, which means my office’s periodic visits can be a number of years apart. A smaller number of police forces, say under 20, would mean we could undertake biennial visits, which would be preferable. In the legislation creating the new oversight body, I hope these visits will have a statutory footing.

• Section 63G of the Police and Criminal Evidence Act 1984 (PACE) empowers police forces to make an application to me to retain the biometrics (DNA profile and/or fingerprints) of an individual with no previous convictions who is arrested for, but charged with, an offence set out in section 65A of PACE. Use of this power by forces is reported in the annual report the BSCC is required to provide to the Home Secretary, and which is published on my web pages. Not all forces use the power, for a variety of reasons, and my small team works hard to encourage its use through awareness-building and provision of workshops and 1-2-1 training sessions where capacity allows. A smaller number of police forces will make this easier for my team, and I would hope there will be greater uptake of this under-utilised tool.

• The new oversight body is likely to have a statutory requirement to engage and coordinate with other relevant regulators and service providers, which I welcome as a means to ensure it is clear to both practitioners and the public who is responsible for oversight in what can appear a crowded regulatory landscape. This is likely to include policing, His Majesty’s Inspectorate (HMICFRS), and whatever may (or may not) replace Police and Crime Commissioners, so careful thought needs to be given to how this is formalised to ensure limited or no crossovers, and avoid duplication of effort.

• This is also an opportunity for police forces and local authorities to review their shared working practices and agreements, particularly with regards their use of surveillance cameras. As these relationships are traditionally geographically-driven, it is important that revised, well-considered agreements are agreed and put in place before they are needed, to avoid any rushed, reactionary actions which may result in an adverse outcome.

• Finally, I welcome the proposal to centralise some functions, particularly so procurement. In the six months since my appointment as BSCC, and as an academic specialising in surveillance beforehand, I have spoken to and been made aware of several forces seeking to purchase, or having already purchased, new biometric and AI-assisted technologies without, it appears to me, fully understanding the capabilities of the technology and the implications of its deployment. The 2022 survey my office conducted on the use by police forces of overt surveillance camera systems in public spaces^{[footnote 3]} (which I intend to repeat this summer with forces and local authorities) highlighted issues with procurement process, including the need for thorough due diligence of all aspects of equipment as an early part of the procurement process. The survey found no evidence that forces used the national decision making model in the procurement process. I hope that robust processes will be put in place when centralising procurement.

This is a unique and important opportunity to shape the future of policing, and my team and I look forward to working with stakeholders at all levels to better deliver for the public.

Professor William Webster
Biometrics and Surveillance Camera Commissioner for England and Wales
13 May 2026

1. Legal framework for using facial recognition in law enforcement - GOV.UK ↩

2. Commissioner’s response to the live facial recognition consultation - GOV.UK ↩

3. Police survey 2022: responses and key findings - GOV.UK ↩