Scotland’s biometrics commissioner calls for new public surveillance strategy

Scotland’s Biometrics Commissioner is calling for a new national strategy for public-space surveillance, arguing that the country’s 2011 CCTV framework no longer reflects the realities of AI-enabled analytics, live facial recognition and modern policing.

Scotland’s current strategy predates the emergence of AI-powered video analytics and live facial recognition. Unlike England and Wales, Scotland also lacks an independent surveillance camera commissioner and dedicated code of practice, leaving oversight largely dependent on general UK data protection laws, Plastow argues.

In 2019, a sub‑committee delayed the rollout of digital triage kiosks over legal concerns, despite subsequent confirmation of their legality. In 2020, the same committee concluded there was no basis for Police Scotland to invest in live facial recognition. “I did not agree with that position in 2020, and I do not agree with it now,” Plastow writes.

Plastow argues the policy gap is becoming more apparent as facial recognition expands beyond policing. While Police Scotland has yet to deploy live facial recognition operationally, the technology is already becoming commonplace in the private sector.

Grocery store chain Sainsbury’s is known to be tripling deployment of Facewatch facial recognition across UK stores and Tesco is expanding its use of Auror’s platform.

Meanwhile, police forces in England and Wales are investing in biometric surveillance, with the Home Office strategy funding nationwide deployment following successful trials by London’s Metropolitan Police. Scottish police are preparing to invest in face recognition with the federation weighing policies to request mask bans. A new project has also been launched to consider how Scottish police’s use of real-time face biometrics should be governed.

“At a time when overall crime in Scotland including sexual crime has increased, when police officer numbers have fallen significantly since 2013, when there are pressures on police budgets, and when more and more criminals are the subject of early release from prison, a strategic shift from ambivalence to assurance in government thinking on all forms of public space surveillance and oversight mechanisms is now required,” Plastow urges.

The debate has shifted

The Scottish National Party passed a motion in 2025 opposing police use of facial recognition, though the current Cabinet Secretary for Justice has since acknowledged the operational independence of the Chief Constable. In the HMICS Annual Report 2025-26, published in April this year, Scotland’s HM Chief Inspector of Constabulary urged Police Scotland to accelerate procurement of live facial recognition technology, drones and AI, arguing that they will be central to the next phase of policing reform.

The Scottish government is reviewing whether to extend the remit of the Scottish Biometrics Commissioner and introduce a surveillance camera code of practice. The review could potentially modernize oversight and deliver a more cohesive public space surveillance strategy. Former UK Biometrics Commissioner Fraser Sampson believes biometrics are an urgent agenda item for police oversight boards.

“Balancing [biometrics’] growing operational importance with an urgent need for public assurance, AI-enabled biometrics must be governed by clear systems, consistent processes and coherent policies – not just in policing but in every organisation using the technology,” Sampson wrote for Biometric Update.

“What this will need most of all is accountability, which is the principal function of the board. That’s why AI-enabled biometrics should be a standing item for all police oversight bodies.”

Article Topics

biometrics  |  facial recognition  |  law enforcement  |  Police Scotland  |  Scottish Biometrics Commissioner