Scottish police taking less children’s biometrics, Code working, Commissioner says

Police in Scotland are collecting biometrics from arrested children less frequently, and the country’s Code of Practice for biometrics collection, retention and use is working well, according to a review by Scottish Biometrics Commissioner Dr. Brian Plastow.

Plastow recommended in a 2023 report that Scottish police strengthen their policy around the collection of biometrics from young offenders and keep children under 18 years old out of the adult system.

Police Scotland changed its policy in March, 2024 to only collect biometric data from children arrested for violent or sexual crimes, or in exceptional circumstances.

The change led to a 7.5 percent drop in the number of children whose biometrics were collected by police, according to the First Statutory 3-Year Review of the Scottish Biometrics Commissioner Code of Practice. Just over 2,000 children’s biometrics were collected in 2023-2024, compared to 1,851 in 2024-2025.

The Code was the first of its kind in the world, introduced in 2022.

“I continue to hold the view that the age of criminal responsibility in Scotland at 12 years of age is still too low, and I support the support the position of the Children and Young People’s Commissioner for Scotland and agree that criminalising children at the age of 12 is an unacceptable situation and it needs to change,” Plastow wrote in the report.

The report also tracks the number of complaints filed under the Code. For 2025, there have been four complaints so far, two of which were closed after they were found unrelated to biometrics or the Code. No breaches of the Code have been found yet, in the three years since its passage.

Plastow also reiterated his conditional support for the use of live facial recognition by Scottish police. Any use should be proportionate, necessary and compliant with the Code of Practice. Primary legislation would improve legal safeguards.

The Code will have to evolve to keep up with circumstances, including the passage of the UK’s The Independent Commission for Reconciliation and Information Recovery (Biometric Material) Regulations 2024, and the new UK Data (Use and Access) Act 2025. A new version should come some time in 2026 or 2027.

Article Topics

biometric data  |  biometrics  |  children  |  data collection  |  Police Scotland  |  Scotland  |  Scottish Biometrics Commissioner