The Scottish Police Authority (SPA) has published a discussion paper exploring the potential adoption of live facial recognition (LFR) technology by Police Scotland. Released in April 2025, the paper is intended to initiate a national dialogue on the ethical, legal, and operational implications of LFR in policing. While there are no immediate plans for implementation, the SPA emphasizes that any future policy decisions will follow broad public engagement and stakeholder input.
The document outlines several scenarios where LFR could be used to enhance public safety and policing efficiency. These include identifying individuals who pose risks—such as registered sex offenders or persons wanted for serious crimes—at large public gatherings, transport hubs, nightlife venues, and major indoor events. The SPA links these use cases to broader strategic priorities, including Scotland’s Violence Against Women and Girls Strategy and efforts to locate missing persons.
Any deployment of LFR, the SPA states, would be governed by the principles of proportionality, necessity, and respect for individual rights. Proposed safeguards include formal risk assessments for each use case, transparent governance structures, and independent oversight. These would be supported by existing bodies such as the Biometrics Oversight Board and Police Scotland’s internal biometric data portfolio holders.
Police Scotland currently uses retrospective facial recognition (RFR) for post-incident investigations but does not employ live systems. The Scottish Biometrics Commissioner has raised concerns about data quality, lack of accuracy audits, and illegal retention of custody images in the Police National Database (PND)—issues that must be addressed before any move toward real-time deployment.
The SPA’s initiative reflects growing interest across the UK in standardizing facial recognition policy. A recent report from the Biometrics Institute called for unified national guidelines, highlighting risks of mass surveillance, algorithmic bias, and declining public trust. In England and Wales, where police use of LFR is more advanced, critics have questioned the adequacy of its common law foundation and called for clearer statutory regulation.
Public opinion in Scotland remains divided. While polling data cited by the SPA indicates that a majority of respondents feel “comfortable” with biometric identification in policing, this support has declined in recent years. Civil liberties groups such as StopWatch argue that LFR poses risks of discriminatory impact, function creep, and a chilling effect on public behavior if not subject to strict legal and ethical controls.
The SPA paper describes the current effort not as a formal consultation, but as a “public conversation” designed to surface concerns and inform future direction. Next steps include gathering public and stakeholder feedback, reviewing alignment with UK-wide guidelines, and conducting ethical and legal assessments of any proposed deployment.
The debate in Scotland unfolds against a backdrop of increased UK government investment in LFR technology and claims of its transformational impact on law enforcement. Yet in Scotland, the absence of a statutory framework and growing scrutiny from oversight bodies suggest a cautious, deliberative path forward. The SPA’s approach—anchored in transparency and public accountability—may serve as a model for responsible innovation in biometric policing.
Sources: SPA Discussion Paper, Biometrics Institute, Scottish Parliament Report
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April 21, 2025 – by Ali Nassar-Smith
