Scottish biometrics commissioner launches new strategic plan

The Scottish biometrics commissioner, Dr Brian Plastow, has launched a new four-year plan to review the use of biometrics by Police Scotland.

The plan includes a mission to promote public awareness around the use of biometrics in policing, while also detailing plans for four in-depth assurance reviews that will be published over the next four years.

The first review, scheduled to be published next spring, will focus on the acquisition, retention, use and destruction of fingerprints collected for criminal justice and police purposes.

“Biometric data such as fingerprints and photographs have been used in policing and criminal justice in Scotland as a means of verification, identification and exclusion for more than one hundred years,” said Plastow.

The new plan comes after a controversial decision taken by Police Scotland in September to move ahead with plans to introduce live facial recognition technology (LFR) amid an ongoing row over its potential breach of human rights legislation. 

The move has faced significant pushback from political parties. A resolution passed at the SNP annual conference last month called the technology the tool of an “authoritarian” state and opposed its implementation.

Reflecting these concerns, the strategic plan outlines how the field of biometrics has evolved over the last 10 years, with “exponential” growth experienced in the sector as new technologies like artificial intelligence (AI) and LFR are implemented.  

“These issues raise important questions for society, including how best to balance our need for public safety and security with broader privacy, ethical, human-rights, and equality considerations,” said Plastow. “The principles of proportionality and necessity, and the long-established principle of policing by consent in Scotland, suggest the need to be careful about the extent of future encroachment.”

The reviews will look at a range of areas, including a review of the policy and practice in relation to the data obtained by Police Scotland from electronic devices including phones, computers and smart watches. The commissioner will also look at the collection and use of data from the body worn cameras worn by Police Scotland officers and staff.

“There have long been concerns about the way in which Police Scotland is holding and using biometrics, so I am pleased to see the Commissioner taking steps to investigate this further,” said Scottish Liberal Democrat justice spokesperson Liam McArthur.

“If biometric data is to have positive outcomes for Scottish policing, more must be done to ensure it is used in a proportionate, necessary and safe manner.”

In a previous assurance review published by Plastow in 2024, it was revealed that Police Scotland did not know the total number of images held in the criminal justice system. The report stated that the exact volume of the images held was not “not easily accessible or possible to determine,” but added that the number is “significantly higher” than all other biometric data types combined.

“The areas in which we propose to conduct our thematic assurance reviews are linked to our duty to support and promote and take cognisance of areas of risk with a preventative focus,” said Plastow. “With our strategic plan we aim to deliver measurable outcomes that support public safety, protect individual rights, and uphold the integrity of biometric practices across Scotland.”