The UK Biometrics and Surveillance Camera Commissioner has called for stronger inspection powers, a broader remit, and a clearer separation between regulating and promoting biometrics, in a formal response to Scotland’s review of the Scottish Biometrics Commissioner’s functions.
Professor William Webster, who holds the biometrics and surveillance camera oversight role for England and Wales, submitted the response to a consultation examining whether the Scottish Biometrics Commissioner remains fit for purpose roughly six years after the office was created by the Scottish Biometrics Commissioner Act 2020. The Scottish role was established to oversee the lawful, proportionate, and ethical use of biometric data by policing bodies.
The response credits the office with delivering a statutory Code of Practice, assurance reviews, and a Strategic Plan, describing it as the first dedicated specialist biometrics oversight body in Scotland. It also raises concerns. Webster warns that the commissioner’s independence may be compromised by a duty to promote the use of biometrics alongside the duty to regulate it, and that limited capacity and insufficient inspection powers restrict effective oversight.
Among the recommendations are stronger powers for inspection, audit, and compliance enforcement, and statutory requirements for public awareness and engagement. The response argues for expanding the commissioner’s remit beyond policing to include the Scottish Prison Service and other criminal justice bodies, all public bodies using biometrics for law enforcement and safeguarding, and public-space surveillance camera systems operated by local authorities. It also calls for a dedicated surveillance camera code of practice for Scotland.
Webster additionally flags divergence between the regulatory regimes in England and Wales and in Scotland, recommending cross-border coordination mechanisms for managing shared biometric data and statutory requirements for independent testing of emerging technologies such as facial recognition.
The response follows the Scottish government’s decision to launch the statutory review of the commissioner’s powers and oversight scope. Webster took up the UK biometrics and surveillance camera role in November 2025 after the post sat vacant, and previously served on the Scottish Biometrics Commissioner’s advisory board.
The recommendations arrive as policing bodies in Scotland weigh wider use of biometric tools, including facial recognition, and as questions persist about how oversight should keep pace. A broader remit and firmer enforcement powers would move the Scottish office closer to a general-purpose biometrics and surveillance regulator rather than one focused on police use alone.
Sources: GOV.UK
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By the ID Tech Editorial Team
