The Information Commissioner’s Office (ICO) has made it clear that Facial Recognition Technology (FRT) is a regulatory priority due to its potential risks and impact on individuals’ rights. While the ICO is currently auditing UK police forces, it has also taken enforcement action against private sector organisations. This signals a growing likelihood of increased scrutiny across all sectors using FRT—particularly where biometric data is processed without clear justification or safeguards.

Our FRT Audit Service is designed to help UK businesses proactively prepare for potential regulatory attention. Acting as your independent governance, risk, and compliance partner, we provide a structured review of your current FRT practices—identifying gaps and risks before the regulator does.

What We Do

Our audit service aligns with the ICO’s key areas of focus, including:

• Governance of FRT Use
  Evaluation of oversight structures, accountability mechanisms, and decision-making processes to ensure responsible deployment.
• Data Protection Impact Assessments (DPIAs)
  Comprehensive review of your DPIAs to ensure they are complete, effective, and compliant. A robust DPIA is a legal requirement and a cornerstone of lawful FRT use.
• Retention and Use of Personal Data
  Assessment of data handling practices to ensure they meet legal standards, including necessity, proportionality, and data retention policies.
• Staff Training and Awareness
  Evaluation of training programmes to ensure staff understand their responsibilities when handling biometric and personal data.
• Safeguards and Controls
  Review of technical and organisational measures in place to protect data and maintain public confidence.
• Necessity & Proportionality Challenge
  Analysis of whether FRT is essential for your business purpose, exploration of less intrusive alternatives, and documentation of decisions to ICO-defensible standards.
• Data Minimisation & Format Review
  Verification that irreversible biometric templates are used where possible, and that raw image retention is strictly limited and legally justified.

With increasing regulatory attention and public scrutiny, businesses must demonstrate that their use of facial recognition is transparent, justified, and compliant. Our service helps you build a defensible position, reduce regulatory risk, and strengthen public trust.

The lawful, fair and proportionate use of FRT requires ongoing oversight, continuous improvement, and regular reviews to respond to evolving legal, ethical and public expectations.

The Benefits of a Pre-Audit

• Regulatory Readiness
  Anticipate and address potential compliance issues before they attract regulatory attention. Be prepared for future ICO scrutiny as oversight of biometric technologies increases.
• Public Confidence
  Demonstrate a proactive commitment to transparency, accountability, and ethical use of facial recognition—key to maintaining trust with customers, employees, and the wider public.
• Operational Assurance
  Provide leadership with confidence that FRT is being deployed responsibly, with clear governance, lawful justification, and defensible safeguards.
• ICO-Defensible Documentation
  Strengthen your position with evidence-based documentation covering necessity, proportionality, and data minimisation—areas most often challenged by regulators.