Tuesday, April 16, 2024

It's been a while...

January 2023 - after 15 months of the ICO looking into the use of facial recognition (FR) being used by schools, supplied by CRB Cunninghams, it deemed that the use of FR with children in schools was 'likely to have infringed data protection law' ...but the ICO were not taking any action.  

Instead they decided to write a Case Study on FR in schools - basically a 'how to do this with our blessings' piece.

After campaigning to get this completely inappropriate biometric technology out of schools for the last two decades the ICO's lack of action on this was a surprise and blow.  Here are a list of the breaches the ICO identified of GDPR and Data Protection legislation (all found here):

    Article 35             - Data Protection Impact Assessment

    Article 5 (1)(a)     - lawfulness, transparency, fair processing

    Article 5 (1)(e)     - storage

    Article 12             - child friendly language

    Article 13             - right to be informed

    Article 6 and 9     - data minimisation, lawfulness, transparency, fair processing

John Edwards the Information Commissioner is choosing to do nothing about the likely unlawful use of FR and biometric fingerprint systems in around 75% of UK secondary schools.

Ruling from around the EU on this are from Sweden, France, Poland and Bulgaria:

All above EU schools were found to be in breach far less than UK schools but yet John Edwards and his ICO team choose to do nothing about the use of the use of biometrics in schools here.

So imagine my surprise today, reading from Jon Baines at Mission de Reya, that the same John Edwards and team decide to "issue[s] enforcement notices ordering Serco Leisure and community leisure trusts to stop using FRT and fingerprint scanning to monitor workers’ attendance" and for only breaching Article 5 (1)(a), 6 and 9.  Serco have been given 3 months to halt their use of biometrics or face a £17.5m fine or 4% of Serco's annual worldwide turnover - phew!!  Seems the ICO are really not happy bunnies with Serco using biometric technology on their employees.   

What about the millions of children using biometric technology in schools?   Looks like the ICO is not bothered about kids biometrics - obviously.  Maybe the fines aren't as lucrative, maybe the optics look bad fining schools?  ...who knows.

Having been utterly deflated after the ICO's reaction to schools using FR (and therefore fingerprints) I presumed I would have to wait until John Edwards is replaced in 2027 for a more deserved ruling, as where could I go if your own Information Commissioner is not enforcing the very legislation he is paid for?

Now it seems the ICO is enforcing the legislation with some bias here, something I'm sure Mr Edwards isn't meant to do.

Tuesday, October 11, 2022

Facial Action Coding System (FACS) assessing emotions - is this a biometric?

When is facial recognition not facial recognition?  And when a school uses a facial action coding system (FACS) to analyse, in real time, a class of children's muscle movements from their face and body, not using a child's image, is this classed as biometric data processing?  This is a question I shall be asking the Information Commissioner's Office (ICO).  

Just to note, a child's fingerprint is not stored as an image but an algorithm - classed as a biometric, when processed in a school setting.

From a lay persons point of view, for the FACS to work it would have to first recognise that there are faces in front of the lens to process - hence facial recognition, therefore a biometric.  But as the system is not using the biometric to identify a specific human can we say that the school is processing an individuals biometric?  I would say yes, because without the collective children or individual child in front of the lens FACS would not work.  FACS can only work with biometric analysis.  Bio 'life' metric 'measure'.

FACS are employed in the Sens equipment being used in Smestow Academy.  Confirmed by the supplier ViewSonic's tweet.

The last couple of sentences of the second tweet is interesting:

"...we are in the early days yet.  Machine learning models take time to evolve."

Are the kids at Smestow Academy helping a FAC system "evolve"?  Is that ethical?  Do the parents and kids know they are helping to "evolve" a private company's commercial product, using the children's biometric muscle movements? 
How a Facial Action Coding System concludes - happiness, sadness, surprise, fear, anger, disgust, contempt.  

FACS potentially looks at lip, brow, nose, chin, neck data, nostril, jaw data whether muscles are tight or loose, head and eye movement, eyes blinking open shut, how much of the face is visible, shoulder shrug, sniffing and whether or not a smile is genuine... a lot of data.  

Here is the FACS inventors description of the technology:

Monday, October 10, 2022

UK schools using classroom biometric technology, data-scraping students faces to detect emotional engagement in lessons

I am writing this in frustration.  There is a video doing the rounds on Facebook and Twitter about schools in China using facial recognition to determine children's attentiveness in class.  It is understandably shocking to see this type of biometric facial/body scanning technology being used on children and the comments relating to the videos relay this.  

Little known is the fact we have the very same biometric technology operating here in UK schools, using biometric facial and body recognition data capture of students to generate 'mood indexing' information relayed in real time to the teacher in the class and school leaders.  It is called Sens and it is supplied by ViewSonic.  ViewSonic's Sens uses Intel's 'OpenVINO toolkit'. 

"To improve engagement rates, Sens measures every student’s facial expression for real-time tracking.  

Track reaction in real-time. From the front row all the way to the back of the room, dual lenses collect data from a full view of the classroom."

Sens biometrically captures a child's 5 emotions:  Happy / Sad / Upset / Amazed / Attentive and dutifully sends the teacher a real time alert to their phone to tell them how the lesson is going.  Placed on top of the white screen the lens silently acquires the breadth and depth of the classroom's human participants emotions.

(Above images from ViewSonic UK Youtube video detailing their collaboration with the City of Glasgow College)

How have we got to this type of technology being used in UK schools?  Simple - through a complete lackadaisical attitude from the UK Department of Education and an Information Commissioner's Office that is, and has been, devoid of regulating children's use of biometrics in schools over the past 2 decades.

The lack of due diligence displayed by these two institutions has enabled the use of biometric technology in schools to step over the boundary of services - using a face to buy a bag of chips, a fingerprint to access a library book - into the classroom to monitor students emotions.  Chinese style.

Okay, we have the consent in the Protection of Freedoms Act, the only legal right children have in schools to say no to their data sharing, but this is not well known and parents and students lack the knowledge of this IMHO, which is a shame because now we have sleepwalked into this situation where pupils emotions are being logged via biometric technology.

Biometric data is the most sensitive and irreplaceable data a child will ever own.  Why are schools using this data to see how students are engaging in a lesson?   

If a teacher cannot humanly know how their class is responding to their delivery of a lesson, either they are in the wrong job or maybe use the money spent on 'mood indexing' children to create smaller class sizes so teachers can 'get' how the lesson is going?

If 'mood indexing' biometric technology is accepted in UK primary and secondary schools by the Department of Education and ICO - then let's lead by example!  The next deployment of this surveillance technology surely should be installed in the House of Commons and Lords... live real time emotional engagement of our elected representatives.  Fantastic!


Smestow Academy, Wolverhampton - Youtube Hybrid learning at the academy, Freedom of Information request, written question asked in the House of Lords (Sept 2022) by Lord Scriven.  ViewSonic's case scenario.

City of Glasgow College - Youtube, Freedom of Information request, ViewSonic's case scenario 

There are another 3 schools, primary and secondary, in the UK that may be using Sens.  More on this to follow.

Thursday, August 18, 2022

Facial recognition in UK schools - the 'right' or 'wrong' type of biometric to be used with children?

10 months after the suspension of facial recognition (FR) at all the secondary schools in North Ayrshire Council, the Information Commisisoner's Office (ICO) has not yet issued any opinion on the use of FR in schools but are expected to publish this on their website in the near future (from their response to a Freedom of Information request received August 2022).  

The very much sooner the ICO issues their opinion the better.  We are seeing biometric analysis of children's bodily and facial data taken in schools, move from services, such as canteen and library, to classrooms monitoring emotional engagement.

A brief history of facial recognition in UK schools:


Facial recognition was first used in UK schools.  Schools from Northamptonshire, Hertfordshire and Cambridgeshire used FR from September 2010 for registration.  The FR system was ‘faceREGISTER’ supplied by Aurora Computer Services, now part of Causeway.

Enquiries to the then Sir Christopher Hatton School, a comprehensive in Wellingborough, Northamptonshire, (now an academy) revealed that the system was scrapped after a few terms.

Since this instance, FR was not used in UK schools until 2020.


FR was trialled in the summer term of 2020 at Kingsmeadow Community College for canteen payments.  It was fully implemented in the Autumn term of that year. 

The FR uses the School Information Management System (SIMS) photograph as a template.
The students present their face at a scanner at the point of sale (POS) to pay for their food.

The school is part of a pilot scheme and no funds were spent on the FR system.

If students do not wish to participate the person at the POS can identify the child by their photograph.

More information here.

FR supplied by CRB Cunninghams.


CRB Cunninghams are supplying around 70 schools with FR technology.

In October North Ayrshire Council (NAC) implemented FR from CRB Cunninghams into 9 of its secondary schools.  The technology last a week.  It was suspended due to concerns from civil liberties groups and and parents.  The ICO paused the technology to review its acceptability under Data Protection Act 2018 and GDPR.

West Lothian Council (WLC) were planning on implementing FR in their 11 secondary schools.  In a January 2022 response to a Freedom of Information request they state, “WLC had begun to consider cashless catering in secondary schools using facial recognition, but this has not been progressed

It was unclear by the end of 2021 how many of the nearly 70 schools had gone ahead with their FR technology.  David Swanston, managing director of CRB Cunninghams stated, “some schools had shown concerns about the system as a result of the reporting on the North Ayrshire schools and the company is planning on issuing a statement to reassure them next week.”  That statement to schools, as far as is known, never appeared on CRB Cunninghams website.


March PRNewswire reported that Smestow Academy, in Wolverhampton, are using a brand new type of facial/bodily scanning of students to determine their wellbeing in the classroom… “the first school in the UK to deploy the AI-powered myViewBoard Sens analysis tool in the classroom.” supplied by ViewSonic.

Through the real-time insights generated by the intelligent sensor, the school can ensure the classroom follows the wellness compliance, increase students' engagement, and facilitate a safe and active learning environment for the best possible learning outcome.

Smestow Academy are working with Intel and ViewSonic to develop “experimental hybrid learning rooms” within the academy - see 1 minute 59 seconds in this video - creating a "software ecosystem" to "add facial-expression recognition and mood indexing to better respond to learners' needs based on non-verbal cues"

April - Biometric Update reported that Stonyhurst College would be implementing FR in 2023 which “will have mobile and facial recognition with two-factor authentication to minimise occurrences of students and staff copying PINs” for door access.  The FR entry system is supplied by Suprema.  A case study video from Suprema ID showcases the company’s 50 biometric and mobile security reader devices in use at Stonyhurst College.

Suprema also provide Wolverhampton Grammar School with FR door access with an additional feature to read the body’s temperature.

June - A parliamentary House of Lords debate on Biometrics Technologies on the use of FR in schools.  Lord Scriven asks:

Facial recognition technology is now used in classrooms to monitor children’s mood and engagement, despite some parents objecting. The biometric regulator has no powers to enforce compliance with the law in schools and the department does not even monitor the use of this technology. Why are the Government taking this approach, allowing private companies’ marketing departments to determine the parameters of our children’s civil liberties and privacy in the classroom?

July - the Department for Education (DfE) issued new guidance on the use of biometric technologies in schools, with notable changes to include FR.  Seemingly some types of FR are acceptable:

Schools and colleges must establish that facial recognition is both necessary and proportionate within the school and college environment.”... with no explanation from the DfE how FR could be necessary or proportionate in schools.

Live facial recognition is not appropriate in schools or colleges.” (A tiddybiddy round of applause here I suppose).  It appears the the DfE is deciding which biometrics are acceptable for use on children in schools when legislations, such as the Data Protection Act 2018 and GDPR, do not offer parameters of acceptable levels.  

Other data regulators in the EU, under GDPR, have halted the use of FR and fingerprints scanners in schools, with fines issued to schools using biometric technology in Sweden, France, Bulgaria and Poland.

August - CRB Cunninghams removed a webinar, detailing the learning capabilities of the FR system they are supplying to schools, from their website and Vimeo.  In the spirit of transparency for students and parents to make an informed decision on consent as to whether they participate in this FR technology, this is how students facial biometric data is used and processed - the webinar exists here:

"the idea with the third template is that this will be updated every 3 months" 17mins 1s
"the algorithm grows with the child" 17mins 20s
"the system will match that for you by constantly evolving the algorithm to match the child's growth and change of appearance" 17mins 49s


Our data regulator, the ICO, has yet to publish their opinion on schools processing students facial biometric data - or body movements to give emotional data to school leaders and Intel (if they even know about this?)

Though I’m not sure how an opinion can be had on the use of biometric technology in schools when legislations explicitly detail how this technology should not be used with children when other less data intrusive systems will suffice -  and less data intrusive systems do exist in a lot of UK schools... PINs, swipe cards, etc.  And especially when other equivalent EU data regulators follow those legislations and do not hold opinions on the 'right or wrong biometrics' to be used with children.

Wednesday, May 11, 2022

State of Biometrics 2022 - a review of policy and practice in UK education

I co-authored a report with Jen Persson from DefendDigitalMe, 'The State of Biometrics 2022 - a review of policy and practice in UK education', which was published last week.  There is no collection, monitoring, record of biometric technology in schools held by any UK government department, regulator or commissioner so information in the report was obtained by Freedom of Information requests and research collated over the number of years I've been doing this blog.

There is definitely further research and questions to be answers and issues to be resolved following the publication.  

Biometric technology has crept from school services, canteen, library, etc, into the classroom - where 'sensors' (cameras) now scrape data from children into a group view for teachers and management to gauge real time interest in lessons, engagement, attentiveness and emotion.  This behavioural data capture is classed as biometric data under the Protection of Freedoms Act, Chapter 2 (28)(2).

From PRNewswire:

"ViewSonic Corp., a leading global provider of visual solutions, has partnered with the Smestow Academy in Wolverhampton, England, as the first school in the UK to deploy the AI-powered myViewBoard Sens analysis tool in the classroom. Through the real-time insights generated by the intelligent sensor, the school can ensure the classroom follows the wellness compliance, increase students' engagement, and facilitate a safe and active learning environment for the best possible learning outcome."


The Report in summary

The Protection of Freedoms Act 2012 and weak enforcement of data protection law are failing to protect millions of children from the normalisation of routine use of biometric data for everyday canteen and library transactions, and increasingly intrusive bodily surveillance in the classroom. 

Pupils in the UK are effectively guinea pigs in the use of emerging technology for companies from around the world, including facial recognition technology that has already been banned from schools in other countries.

Some companies claim that their products can measure mood and attentiveness, or use artificial intelligence to manage behaviour-based classroom planning. Some companies even claim to be able to detect autism without any child development expertise.

How this normalisation and these emerging products may affect the full and free development of the child are yet to be seen.

The fast-growing uses of intrusive technology involving bodily data in educational settings worry child rights advocates and law makers alike. 

Lord Paul Scriven said, “As parents you should be very worried and angry that private companies are seeking to make a profit from your child’s face, fingers, eyes and other personal characteristics while trying to pretend that it is all to aid their educational attainment. Where do we draw the line?”

  • Data from FOI requests to schools (all UK) Our findings from enquiries to 550 schools with over a quarter of a million pupils in total, suggests that around three quarters of secondary schools are using fingerprint technology or other biometrics, and where used, uptake is routinely 85%, or more where use is restricted to only certain year groups.
  • Despite the law requiring consent some schools in England are discriminating against children in receipt of Free School Meals (FSM) by obliging them to use the fingerprint systems, and others make it obligatory for all pupils. (We are yet to quantify these issues and plan to continue further research.)
  • Emerging technologies, school trials and scope creep including under COVID. Schools started using facial recognition more widely in 2020. At least one school got new facial recognition technology free, “as part of a trial”. Some schools combined entry access readers with thermal and facial detection. Some are trialling “experimental” products including attentiveness and mood detection that are unevidenced in their intended outcomes or in any unintentional effects on children’s behavioural and cognitive development in UK classrooms. Voice is rarely considered under school biometrics policies whereas fingerprint technology is now routine.
  • Lack of regulatory enforcement. Six months after North Ayrshire schools in Scotland put their facial recognition rollout on pause, there has been no visible ICO regulatory enforcement action. We include a latest position statement in the report.
  • Large multinational companies have bought out the originally small school biometrics suppliers and many significant UK school providers are owned in the US, Canada and Israel.
  • Parents’ survey findings (2018) Survation polled 1,004 parents with children in state schools on behalf of defenddigitalme about their experience of technology in schools. Over a third of parents (38%) whose children were using biometrics in school, said they had not been offered any choice despite the law that requires parental consent, the Protection of Freedoms Act 2012, and over 50% of parents had not been informed how long their child’s  fingerprints or other biometric data is retained or when the data would be destroyed.

Professor Fraser Sampson, Commissioner for the Retention and Use of Biometric Material and Surveillance Camera Commissioner and author of the report foreword, suggests there is inadequate oversight of school procurement among wide ranging comments.  “Some – including, surprisingly, the Department for Education – appear to have taken the view that bare compliance with Chapter 2 of the Act is all that is required to ensure the lawful, ethical and accountable use of biometric surveillance in schools.” He asks five key questions of practice in schools: Who's benefiting? Who's watching? Whose company are you keeping? Where's the push? And, Why the rush?

There are no UK national requirements for any quality or health and safety standards of biometric or AI technology when used by state schools, and no oversight or record of what is used where.

Current legislation is ineffective in protecting children’s and students’ rights in educational settings from age 2-25 and change is needed now. defend digital me is calling for a ban on biometric systems in educational settings.

Authors: Pippa King and Jen Persson

Artwork: Hannah Mallory

Monday, January 10, 2022

Update on facial recognition in UK schools

Since 2000 biometrics deployed in UK schools are/have been - fingerprinting, facial recognition, iris scanning and infrared palm scanning.

Department of Education and the Information Commissioner's Office (ICO)

  • Do not list any schools using facial recognition (or any other type of biometric, i.e. fingerprint)
  • Have not had any communication with companies that supply facial recognition in schools
  • Have not issued any advice to educational establishments with reference to the use of facial recognition
  • Have not logged any instances of violations of the Protection of Freedoms Act 2012, Chapter 2 - consent to use of a child’s biometric data
  • Have not ever seen biometric hardware or software that are being used in schools
Evidence for this has come from Freedom of Information requests.

Biometrics Commissioners (and Surveillance Camera Commissioner)

  • Have no jurisdiction with regards to children's biometrics, use and processing in education 

Children’s Commissioners UK

  • Have no jurisdiction with regards to children biometrics, use and processing in education 

Legislation - Protection of Freedoms Act Chapter 2, Data Protection 2018 and GDPR

  • Why does the ICO not enforce or rule as other EU countries (FranceSweden, Bulgaria and Poland) have done on the use of biometrics in schools?

What is the point of having legislation, if legislation is not being used or at least monitored for compliance?

Why has the use of children's biometrics slipped through the net of every single government department, various commissioners and an information regulator, ICO, which is meant to scrutinise the use of data - especially when this involves children’s data, with a use of technology that adults do not routinely use?

For over two decades now - biometrics in schools - there should be no excuses of this neglect of responsibility.  An immediate duty in this needs to be allocated to at least one of the above positions and organisations - the fact this has never been done is disgraceful.  

The ICO has yet to rule on the use of facial recognition by North Ayrshire Council, I await with interest its decision (if it is capable of making one).

Tuesday, October 19, 2021

North Ayrshire Council's FOI responses...

I asked a Freedom of Information request (FOIR) to North Ayrshire Council (NAC) and got a response here.  It warrants further investigation on a few issues.  Consent.  Data Protection Impact Assessment.  Cost and claims NAC make of the system to speed up lunch lines and being 'Covid safe'.

Consent.  I have touched on this before but I am curious as to who is determining the age of the ability of the child to consent to using their facial biometrics to pay for food.  In England and Wales where a school wants to take and process a school's biometric, for any child under 18, parental consent is required by legislation

In NAC it seems there was a debate on consent... 12 or 14?  Consideration, though I can't see how this marries up, was that 12 year olds can withhold data on what they eat to their parents therefore they can consent to having their biometrics used.  Am I thick, because I'm not connecting this reasoning up??

But somehow, it appears from advice from the supplier, that in other schools they have opted for 14 - why? ...we don't know - but it's quicker and easier to facial scan kids who can give consent themselves than wait for parents to consent apparently.  See below communications sent to me via FOIR response:

I was interviewed this morning on BBC Radio Scotland about consent, NAC are saying that they have a 97% uptake.  I bet they do, children when asked for consent is simply invalid due to it not being able to be freely given due to the power of imbalance between the school and family, not wanting to be different and peer pressure.  

And how do parents and children differentiate between the finer nuances of facial recognition essentially taken from a still photograph (FR), live facial recognition (LFR) taken from live video feeds and retrospective facial recognition (RFR)  from non live video records?  Parliament can barely eek this out privacy wise so how on earth can a child or parent without some hours research on the topic?

If parents and children could read the Data Protection Impact Assessment (DPIA) done on the system, all 16 pages of it with redactions about data sharing, they might not be so keen to use facial recognition.

But BBC Radio Scotland said, the 'kids and parents like it'.  Erm, so what?  Biometric technology used by children has been discussed in UK Parliament and at EU level and its deemed in legislations, DPA 2018 and GDPR, to be unlawful.  There are lots of things we 'like' and some are legislated against for good reason where minors are involved.

Although only EU regulators have responded to schools using facial recognition and fingerprints to ban it and fine the schools using biometrics in France, Sweden and Poland.  

Why isn't our regulator, the Information Commissioners Office doing this?  A good question that I hope will be resolved soon enough.

Data Protection Impact Assessment - as I mentioned earlier, parts on data sharing are redacted.  In order for full transparency I believe with such a new technology, potentially being unlawfully used, we should see exactly how it is being used.

Cost and claims - again redacted.  This is our tax payers money, we should have a right to know under Freedom of information.

Justification of using FR to 'speed' up lunch lines and covid safe - I think I'd like to see a cost benefit analysis on this 'speed' claim in comparison to the older system and see some statistics on this.  How many seconds are the schools going to save and what will they do with the new found time in the school day?

Same with the covid safe claim, it maybe is who knows?  (I did think because of kids wearing masks that this was an aerosol transmission...?)

A new FOIR with further questions is here.

Friday, October 01, 2021

What is the current situation with facial recognition in UK schools?

This situation with facial recognition technology use in UK schools is unknown, as is the case for the amount of schools using pupils biometric fingerprints.  

Using the Freedom of Information Act and catching the media on this as it happens seems to be the only way  to see how this technology is being rolled out, as schools are under no obligation to inform the Information Commissioner's Office (ICO), who oversees the Data Protection Act (DPA) 2018 and the General Data Protection Regulations (GDPR), that they are taking and processing children's biometric data.

As of this week it appears that North Ayrshire Council, Scotland, are in the process of implementing facial recognition in to its 9 high schools and West Lothian Council, also in Scotland, are looking at introducing facial recognition technology in its 11 high schools - a total of approximately 20,000 students.

In England there are:

Kingsmeadow Community Comprehensive School,  Gateshead

Canon Slade CofE School, Bolton

Murray Park Community School, Derby  - Update 20/10/21:  I have been contacted by Realsmart who have stated, "Realsmart do not provide any systems that work with biometrics". I welcome more clarification on this and will post accordingly.

Langley Park School for Girls, Beckenham

...another 5,000 students and I suspect there are quite a few more schools too.

Consent and Legalities

England and Wales - explicit consent from parents must be sought for a school to take and process a child's biometric, which was, up to now, mainly in the form of a fingerprint template, this now however extends to photographs used for a facial recognition system.  This is law and the legislation covering a schools obligation to gain consent is in the Protection of Freedoms Act 2012 (PoFA).

Both parents need to consent and so does the child.  Any child or parent not consenting overrules the consent of a parent that does consent.  An alternative to the biometric system must also be provided and this alternative option should be made aware to the parent/s child - see page 10 of the governments 'Protection of biometric information of children in schools and colleges' advice to schools.

Scotland and Northern Ireland - here the PoFA 2012 does not apply.  Scottish schools have tended to ask for consent in line with the PoFA but recently seem to have taken it upon themselves, from exactly whose advice is unknown at this time, to presume that S1-S3 pupils need parental consent and S4-S6 pupils can consent themselves.  See North Ayrshire's consent forms S1-S3 and S4-S6.  

S4 students are 14/15 years old, under PoFA no student under the age of 18 can consent to their biometrics being processed by schools.

However, this consent process becomes redundant as indications from Europe show that facial recognition in schools is in direct contravention of the EU legislation GDPR.  Rulings against using facial recognition in schools has been acknowledged by our UK ICO in their June 2021 report, page 22, 'The use of live facial recognition technology in public places':

The report went on to state that: "The research found support for the government imposing restrictions on the use of FRT [facial recognition technology] by the police (55%) and in schools (68%). The Ada Lovelace Institute recommends a voluntary pause on the sale of FRT to enable public engagement and consultation to take place." ...in which case why are UK schools spending tax payers money on this legally questionable technology?

The legalities of facial recognition in UK schools is unknown.  We are still subject to the EU GDPR and under that facial recognition use in schools has been in contravention of the strict use of biometrics with minors that the EU Act cites.  

Our ICO appears unable to answer what communications they have had with educational establishments or companies supplying facial recognition to schools.  A recent of Freedom of Information on this was refused on 30th September 2021, citing Section 12, exceeding costs and time - I am hopeful there may be a disclosure of some information though - see here.

Monday, September 27, 2021

Facial recognition arrives in UK schools

Facial recognition is emerging in UK schools for canteen payments.  The promise of the technology is "to keep pupils safe from allergies and keep the school Covid secure" and to speed up lunch lines, reducing times from however many seconds it was before, to only 5 seconds per pupil 'serve time' with facial recognition technology.  This new biometric technology is, according to the Business Manager at Kingsmeadow School in Gateshead:

 "...just fast!  Better than fingerprints"

The fortuitous supplier of the emerging facial recognition technology is CRB Cunninghams.

Gosh, even faster than fingerprints!  Wasn't that one of the main reasons to introduce biometric technology two plus decades ago?  Because pupils can't forget a thumb but can forget a 4 digit pin or swipe card, hence a thumb on a scanner is faster, right?  Epic fail fingerprint technology - you're obviously just not fast enough.  (Erm... if students can forget a 4 digit PIN what hope have they of passing any exams if their memory is that bad!   Anyway...)

Then is there is the 'Covid secure' reason.  No need to touch anything at the point of sale.  But then a swipe card ticks those boxes too.  The facial recognition technology even works with a mask/face covering... but then so does a PIN or a swipe card.  Plus the hundreds of students passing through a lunch line will have walked through school corridors, placing their hands on the corridor swing doors to get to the dining hall, etc, so I'm not sure the 'Covid secure' reason stacks up.

Then there's the old bullying issue.  According to Ed Tech providers of cashless catering systems, cash in schools = bullying issues.  Well, if that happens the school must sort it out.  Having cashless catering systems in schools won't solve any bullying issues.  As one Reddit user asks 'how can the computer tell if the person isn't being held there by a bully'?  Good question.


According to this article, describing CRB Cunninghams recent introduction of facial recognition to school lunch lines, "CRB Cunninghams have used biometric data since 2008 on the cashless catering system".  Erm not quite so.  Cunninghams have been supplying fingerprint biometric systems to schools in Angus, Scotland, since 1999 according to a Freedom of Information request (FOIR) answer from Angus Council.  As far as is known, this the first use of biometric technology with children in schools in the UK, Europe, USA, Canada, and the western world.

Angus Council FOIR response, September 2018:

Cunninghams introduced biometric technology in schools 22 years ago, before the technology was being used anywhere else regularly in society.  Now it's seems they are at the forefront today pioneering facial recognition technology. 

Lucky Cunninghams, first for both biometric fingerprint and now commercially viable biometric facial recognition technology for kids in schools.  Though by no means the only supplier now.  

Innovate, supplying Langley Park School for Girls in Bromley.   

Canon Slade School Parent Facial Recognition Pdf in Bolton using Cunninghams, and Murray Park Community School Parent Facial Recognition Pdf in Derby using Realsmart  - Update 20/10/21:  I have been contacted by Realsmart who have stated, "Realsmart do not provide any systems that work with biometrics". I welcome more clarification on this and will post accordingly 

I stated commercially viable earlier, as facial recognition was trialled in 2010 in ten UK schools by Aurora, for registration purposes, in Northamptonshire, Cambridgeshire and Hertfordshire.  It was quickly ditched as it just wasn't fit for purpose.  Clearly the technology has matured and is now deemed fit for use on children in schools.

Legalities and consent

Well, this is where it gets interesting and complex and warrants another post really but for a quick view see here.  I'll expand on this more in another post.