WAPI Member Notice: Data Protection and Facial Recognition

THE WAPI NEWS – “ROUNDUP”

WAPI Member Notice: Data Protection and Facial Recognition

A parliamentary question tabled on 9 October asks what ICO guidance applies to private investigators—including registration, personal-data processing and whether investigators should adopt the ABI’s ICO-approved UK GDPR Code. 

This is a question awaiting an answer, not a change in law or an endorsement making the voluntary Code compulsory. 

The Government’s response is due on 13 October and WAPI will review it. (questions-statements.parliament.uk⁠, ico.org.uk⁠)

Separately, updated Home Office policy confirms Immigration Enforcement’s use of facial recognition. It does not authorise private investigators to use the technology. 

For private-sector use, facial images used for identification will usually be special-category biometric data, requiring a lawful basis, an Article 9 condition and normally a DPIA. (gov.uk⁠, ico.org.uk⁠)

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