The Metropolitan Police Service (MPS) is in a substantively different place to South West Police (SWP) due to the procedural steps it has taken. The MPS’s Data Protection Impact Assessment (DIPA) and Equalities Impact Assessment (EIA) are comprehensive, and the MPS is confident that these documents address the issues identified in the Bridges case. The MPS is in the process of reviewing its published documentation to see if these can be further improved.
In summary, the judgment did not find that facial recognition deployments are unlawful generally. The judgement, in fact, recognised the legal basis for police to use LFR technology. In relation to SWP’s specific use of facial recognition technology, it found that SWP left too much discretion in its policy documents for individual officers. Moreover, the court found that SWP’s data protection impact assessment was not compliant and that SWP had not given proper consideration to the risk of bias to satisfy the Public Sector Equality Duty (PSED).
The MPS believes that, through the DPIA and EIA, as well as through associated policy documents (which are published on the website), it can demonstrate compliance with data protection law and the PSED.