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? 

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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:

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!

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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.