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: