Judgment Approved by the court for handing down
R (Bridges) v CCSWP and SSHD
All staff handling South Wales Police information are security
cleared and required to complete annual training on the
importance of security, and how to handle information
appropriately.
In addition to having security guidance and policies embedded
throughout SWP business, SWP also has specialist security,
cyber and resilience staff to help ensure that information is
protected from risks of accidental or unlawful destruction,
loss, alteration, unauthorised disclosure or access.”
SWP Standard Operating Procedures (“SOP”)
41.
SWP has Automatic Facial Recognition Standard Operating Procedures
(“SOP”) which apply to their use of AFR. They were published in November
2018 (i.e. after the dates of the 2 events in question), when a separate facial
recognition section was added to SWP’s website, and the SOPs were published
on that webpage. The SOP’s primary features include (see especially pages 6
and 14):
(1) A stipulation that watch lists should be “proportionate and necessary”
for each deployment and primary factors for the inclusion on watch
lists include will be “watchlist size, image quality, image provenance
and rationale for inclusion”.
(2) The numbers of images included within a watchlist cannot exceed
2,000 due to contract restrictions “but in any event1 in 1000 false
positive alert rate should not be exceeded”.
(3) Children under the age of 18 will not normally feature in a watchlist
due to “the reduced accuracy of the system when considering immature
faces”.
(4) The decision for an AFR deployment wherever possible will ultimately
be made by the Silver Commander.
(5) The rationale for the deployment of AFR is to be recorded in a predeployment report.
(6) Signs advertising the use of the technology are to be deployed to
ensure that where possible an individual is aware of the deployment
before their image is captured.
(7) Interventions are not to be made on the basis of a similarity score alone
and when an intervention is made intervention officer will establish the
identity of the individual by traditional policing methods.
(8) Details of the retention of different types of information gathered
during an AFR deployment.