Using FRT in schools – letter to North Ayrshire Council

We have issued a letter to North Ayrshire Council (NAC) following their use of Facial Recognition Technology (FRT) to manage ‘cashless catering’ in school canteens.

The story was first brought to us in October 2021 when NAC introduced FRT into nine of its schools. NAC stopped processing shortly after data protection concerns were raised with us.

Although FRT and other new technologies can offer benefits within an education setting, they process special category data and are not without risk.

As the data protection regulator, we want to ensure that educational authorities can access the benefits of new and emerging technologies, whilst also protecting children’s data and safeguarding their rights.

FRT and similar technologies can potentially be used lawfully with appropriate assessment and care.

One of the things that education authorities based in England & Wales must also apply is section 26 of the Protection of Freedoms Act 2012 which has provisions around parental & child consent for the use of biometrics in schools. These provisions do not apply in Scotland or NI.

To read the letter in full, please click here.

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