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)
March 19, 2026
Is a Change to Income Tax Devolution in Wales on the Horizon?

An independent report, commissioned by the Welsh government, has examined potential future options for income tax devolution in Wales. It compares keeping the current partially devolved system with moving to full devolution, while factoring in the effects of the block grant adjustment (BGA).

Read article
March 18, 2026
Starting Up in Business: A Practical Guide

Have you reached a point where the idea of running a business feels like more than just a pipe dream? Perhaps you have identified a gap in the market, you want greater independence or your side hustle is telling you that it has the potential to become a full-time income.

Read article