Haines & Company

Guidance for small businesses on using facial recognition technology

Talk to an expert

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)
August 27, 2026
Cost of business crisis for British SMEs

UK businesses are facing a “cost of business crisis”, according to the British Chambers of Commerce (BCC). Its new cost-stack calculator shows government policy alone has pushed up an average firm's expenses by 70% over the past decade, adding roughly £827,000 a year in costs for a typical mid-sized business. About a quarter of the rise stems from the increase in employer National Insurance contributions, with the higher minimum wage and mandatory pension auto-enrolment also major contributors.

Read article
August 26, 2026
Making Tax Digital for Income Tax first quarter statistics published

Under Making Tax Digital (MTD) for Income Tax, sole traders and landlords with income of more than £50,000 have been required to keep digital records and send quarterly updates to HMRC since 6 April 2026.

Read article