Guidance for small businesses on using facial recognition technology
Facial recognition technology (FRT) identifies or otherwise recognises a person from a digital facial image. Businesses can use FRT in a variety of contexts - for example, in allowing access to devices, taking payments, or allowing entry to secure areas.
Depending on the use, FRT involves processing personal data, biometric data and special category personal data. Such technologies can intrude on people's privacy, so businesses need to think carefully when deciding if they should implement them.
If you are a small business looking to begin using facial recognition technology, read the ICO's latest FAQ about using FRT for payment, entry, or other security systems.
The information highlights key issues to be aware of, such as:
- what you need to consider before using this technology;
- when you must complete a data protection impact assessment;
- how to identify and satisfy a special category condition; and
- what to include in your privacy notice if you use FRT. See: [Additional considerations for technologies other than CCTV | ICO](https://ico.org.uk/for-organisations/guide-to-data-protection/key-dp-themes/guidance-on-video-surveillance-including-cctv/additional-considerations-for-technologies-other-than-cctv/#frt)
HMRC have proposed a new criminal offence for making reckless, untrue statements or declarations about what's known as 'direct taxes' - Income Tax, National Insurance and the like. For Customs and Excise and VAT ('indirect taxes'), it is already possible to prosecute individuals who make untrue statements or submit incorrect documents either knowingly or recklessly, without the need to prove dishonesty. The penalties for such offences can be severe, including substantial fines and imprisonment. The direct tax regime does not currently contain an equivalent offence.
A new Freedom of Information (FOI) request has discovered that health and safety violations cost British employers over £44 million per year. The Health and Safety Executive (HSE) revealed that serious breaches have resulted in an increasing number of prosecutions between 2023 and 2025.
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