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