Crime and intelligence - Live Facial Recognition (S5100)

2.1 This policy relates to the use and governance of Live Facial Recognition technology. This is new software recently procured by Essex Police for operational deployment across both Essex and Kent. In particular, the parameters and legal constraints will be outlined to ensure that applications of use are in line with the APP and recent legislation.

2.1.1 Key acronyms: EP means Essex Police; KP means Kent Police; LFR means Live Facial Recognition; AO means Authorising Officer; WAD means Written Authority Document; ZoR means Zone of Recognition. A fuller acronym list is included in section 8.

2.2. This policy will reference appropriate associated procedure documents regarding LFR, links to the college APP and national guidance. More detail about how EP and KP will use LFR can be found in section 6 and within the linked procedure.

2.3 EP and KP are also cognisant of the views and ongoing considerations of the Information Commissioner and relevant biometrics and surveillance oversight bodies, and have participated in the development of national guidance and a code of practice relating to LFR and its use by UK Law Enforcement Agencies (LEA).

2.4 This policy provides EP and KP personnel and members of the public with information about the forces’ strategic, operational and technological objectives for the overt use of LFR. It explains how LFR may be used to support legitimate law enforcement purposes while remaining compliant with law, national guidance and relevant safeguards.

2.5 There are other forms of Facial Recognition Technology (FRT) that are not within the scope of this policy. These include Retrospective Facial Recognition (RFR), which relates to non-real-time searching of images against a database, and Operator Initiated Facial Recognition (OIFR), where an officer takes a picture of a subject using a mobile device and submits it for immediate search. OIFR is fundamentally different from LFR because a human operator has made the decision to submit a specific probe image for analysis and it is not used in a live crowd-scanning function.

3.1 EP and KP use Live Facial Recognition (LFR) as an overt policing tactic to help locate people who are wanted for criminal offences, reduce violence and protect vulnerable people. This policy and the associated procedure documents provide instruction for police officers and staff on the lawful, necessary, proportionate and legitimate use of LFR.

3.1.1 LFR technology uses a live camera feed to scan facial images of people passing through a defined Zone of Recognition and uses advanced algorithms to check those images against a predetermined Watchlist. If the facial image does not match the Watchlist, the biometric template is automatically and immediately deleted.

3.1.2 The aim of this policy is to provide EP and KP personnel and members of the public with clear information about the strategic, operational and governance objectives for the overt use of LFR. All use of LFR must be lawful, ethical, necessary, proportionate and compliant with data protection legislation.

3.1.3 The policy will set out the governance structure in terms of applications, authorities, and then operational deployments.

3.2. Terminology

3.2.1 Within EP and KP and throughout EP’s and KP’s LFR Documents, the following terms and definitions apply in relation to Live Facial Recognition: -

3.2.2 Adjudication

A human assessment of an alert generated by the Live Facial Recognition (LFR) application by an LFR engagement officer (supported, as needed by the LFR operator) to engage and further confirm identification with the individual matched to a watchlist image. In undertaking the adjudication process, regard is to be paid to subject, system and environmental factors.

3.2.3 Administrator

A specially trained person who has access rights to the LFR application to optimise and maintain its operational capability.

3.2.4 Alerts

An alert is generated by the Live Facial Recognition application when a facial image from the video stream is being compared against the watchlist and returns a comparison (similarity) score above the threshold.

3.2.5 True alert

A true alert is determined when the probe image is the same as the candidate image in the watchlist.

3.2.6 Confirmed true alert

Following engagement, a confirmed true alert is determined when the engaged individual is the same as the person in the candidate image in the watchlist.

3.2.7 True recognition rate

It is the total number of times an individual(s) on a watchlist known to have passed through the zone of recognition, correctly generating an alert, as a proportion of the total number of times those individuals pass through the zone of recognition (regardless of whether an alert is generated).This is also referred to as the true positive identification rate.

3.2.8 False alerts

When it is determined by the operator that the probe image is not the same as the candidate image in the watchlist, based on adjudication without any engagement. (The false alert rate is one of the two measures relevant to determining application accuracy).

3.2.9 Confirmed false alert

Following engagement, it is determined that the engaged individual is not the same as the person in the candidate image in the watchlist.

3.2.10 False alert rate

The number of individuals that are not on the watchlist who generate a false alert or confirmed false alert, as a proportion of the total number of people who pass through the zone of recognition. This is also referred to as false positive identification rate.

3.2.11 Application accuracy

Application accuracy can be considered to consist of the combined LFR technology accuracy and the human in the loop decision-making process. Accuracy is determined by measuring two metrics, the ‘True Recognition Rate’ and the ‘False Alert Rate’. This is further explained below. The example given has been simplified to demonstrate the concept, but note that the metrics have been calculated in accordance with the agreed scientific method as set out by the International Organisation for Standardisation:

True recognition rate	False alert race
What is it? It is the total number of times an individual(s) on a watchlist is known to have passed through the Zone of Recognition, correctly generating an alert, as a proportion of the total number of times those individuals pass through the Zone of Recognition. This is regardless of whether an alert is generated by the LFR application or not.	What is it? Is the number of individuals that are not on the watchlist who generate a False Alert or Confirmed False Alert as a proportion of the total number of people who pass through the Zone of Recognition.
The True Recognition Rate would be 90% if 10 people on the watchlist each pass the LFR system, and an Alert is generated correctly for 9 out of 10 of those people (with no alert being generated against the 10th person).	The False Alert Rate would be 0.1%, if for every 1,000 people that passed the LFR system, an Alert was generated against one person who was not on the watchlist.

 3.2.12 Authorising Officer (AO)

The trained and designated officer who provides the authority for deployment of LFR. The AO will normally hold the rank of Superintendent or above, but authority is attached to the designated AO role and relevant training, not to rank alone.

3.2.13 Biometric template

A digital representation of the features of the face that have been extracted from the facial image. It is these templates (and not the images themselves) that are used for searching and which constitute biometric personal data. Note that templates are proprietary to each facial recognition algorithm. New templates will need to be generated from the original images if the LFR application’s algorithm is changed.

3.2.14 Blue watchlist

A watchlist comprises known persons that can be used to test system performance, for example, police officers / staff may be placed on a blue watchlist and `seeded’ into the crowd who walk through the zone of recognition during a deployment.

3.2.15 Candidate image

Image of a person from the watchlist returned because of an alert.

3.2.16 Deployment

Use of an LFR application as authorised by an AO to locate those on an LFR watchlist at a designated location.

3.2.17 Deployment record

An amalgam of the LFR application, the written authority document and the LFR cancellation report. This sets out the details of a proposed deployment including – but not limited to:

1. location
2. dates and times
3. deployment and watchlist rationale
4. legal basis
5. necessity
6. proportionality
7. safeguards
8. watchlist composition
9. authorising officer
10. resources
11. relevant statistics
12. outcomes
13. summary of any issues
14. threshold setting.

3.2.18 Engagement

An officer communicating with a member of the public as a result of an alert. 

3.2.19 Environmental factors

An external element that affects LFR application performance, such as dim lighting, glare, rain, mist.

3.2.20 Faces per frame

A configurable setting that determines the number of faces that can be analysed by the LFR application in each video frames.

3.2.21 Facial Recognition Technology (FRT) 

This technology works by analysing key facial features, generating a mathematical representation of these features, and then comparing them against the mathematical representation of known faces in a database and generates possible matches. This is based on digital images (either still or from live camera feeds).

3.2.22 False negative

Where a person on the watchlist passes through the zone of recognition but no alert is generated. There are several reasons false negatives occur; these include application, subject and environmental factors, and how high the threshold is set.

3.2.23 Gold Commander

Is the strategic commanding officer who assumes overall command and has ultimate responsibility and accountability for the Deployment. (They are responsible and accountable for the policing operation/event and determine the strategic objectives and separate to other force wide daily gold commanders).

3.2.24 Live Facial Recognition (LFR)

LFR is a real-time deployment of facial recognition technology, which compares a live camera feed(s) of faces against a predetermined watchlist to locate persons of interest by generating an alert when a possible match is found. 

3.2.25 LFR engagement officer

An officer whose role is to undertake the adjudication process following an alert, which may or may not result in that officer undertaking an engagement. These officers will also assist the public by answering questions and helping them to understand the purpose and nature of the LFR deployment.

3.2.26 LFR operator

An officer or staff member whose primary role is operating the LFR system. They will consider alerts and, via the adjudication process, will assist LFR engagement officers in deciding whether an alert should be actioned.

3.2.27 LFR system engineer

A person whom EP and KP deem to have suitable technical qualifications and experience to optimise and maintain the operational capability of the EP and KP LFR system.

3.2.28 Person(s) of interest

A person on a watchlist.

3.2.29 Possible match

A person returned because of the probe and candidate image being of sufficient similarity above the threshold.

3.2.30 Probe image

A facial image which is searched against a watchlist.

3.2.31 Recognition time

The average time from when a face appears in the zone of recognition of the camera to when the LFR application generates an alert.

3.2.32 Retrospective Facial Recognition (RFR)

A post-event use of facial recognition technology, which compares still images of faces of unknown subjects against a reference image database to identify them.

3.2.33 Silver Commander

The officer who commands and coordinates the overall tactical implementation of the LFR Deployment in compliance with the strategy set by the Gold Commander. (The silver commander develops, commands, and coordinates the overall tactical response of an operation, in accordance with the strategic objectives set by the gold commander).

3.2.34 Similarity score

Is a numerical value indicating the extent of similarity between the probe and candidate image, with a higher score indicating greater points of similarity.

3.2.35 Subject factor

A factor linked to the individual, for example, demographic factors or physical features or behaviours for example, the individual is wearing a head covering, is smoking, eating, or looking down at the time of passing the camera.

3.2.36 System factor

A factor relating to the LFR application such as the algorithm.

3.2.37 Threshold

The configurable point at which two images being compared will result in an alert. The threshold needs to be set with care to maximise the probability of returning true alerts whilst keeping the false alert rate to an acceptable level.

3.2.38 Urgency

In the context of authorising an LFR deployment, a deployment that is related to an: Imminent threat-to-life or serious harm situation; and/or intelligence / investigative opportunity with limited time to act, where the seriousness and potential benefits support the urgency of action.

3.2.39 Watchlist

A set of known reference images against which a probe image is searched. The watchlist is normally a subset of a much larger collection of images (from the reference image database) and will have been created specifically for the LFR deployment. 

3.2.40 Zone of recognition

A three-dimensional space within the field of view of the camera and in which the imaging conditions for robust face recognition are met. In general, the zone of recognition is smaller than the field of view of the camera, so not all faces in the field of view may be in focus and not every face in the field of view is imaged with the necessary resolution for face recognition.

3.3 Legislative compliance

3.3.1 This document has been drafted to comply with the principles of the Human Rights Act 1998. It pays particular attention to the duties of the force regarding privacy and the rights to assembly, thought and expression. 

3.3.2 The lawful exercise of rights to freedom of expression, association, assembly or protest must not, of itself, justify either the deployment of LFR or the inclusion of a person on a watchlist. Any deployment likely to affect those rights must include enhanced consideration of legality, necessity and proportionality, with clear safeguards recorded in the Written Authority Document.

3.3.3 Equality and Diversity duties and issues have been considered, and this is reflected in the Equality and Wellbeing Impact Assessment that is provided alongside this document.

3.3.4 As with all policies, the duties and obligations of the force regarding Data Protection, Freedom of Information and Health and Safety matters have been considered and complied with, along with The College of Policing’s Authorised Professional Practice (APP) on Facial Recognition Technology.

3.3.5 Whilst appropriate use of LFR as a precision crime fighting tactic delivers clear value to UK Law Enforcement and the public in turn, it is important to recognise that the use of LFR involves biometric processing. EP and KP are conscious that the use of LFR has been the subject of much debate. Areas subject to particular debate and scrutiny relate to intrusion into civil liberties, accuracy concerns, the potential for wide-scale monitoring through the use of LFR, and the possibility of automated decision making as a result of LFR processing.

3.3.6 It is therefore incumbent on EP and KP to ensure that LFR is used lawfully and responsibly for legitimate policing purposes, and in a manner that is transparent. This will help ensure that public trust and confidence is not eroded by the use of LFR.

3.3.7 EP and KP will adopt safeguards consistent with national guidance and good practice. These safeguards are as follows:

3.3.7.1 Each Deployment must be carefully designed and have clear, documented objectives.

3.3.7.2 The Watchlist for any Deployment must be restricted to individuals whose inclusion is necessary and proportionate to the purpose of that Deployment and who are reasonably believed to be capable of being encountered at the Deployment location.

3.3.7.3 There may be an intelligence/evidence case to include a watchlist of individuals who are at risk of serious harm. This will, however, only be those assessed as medium or high risk.

3.3.7.4 In general, deployments will not include watchlists of victims or witnesses. The Authorising Officer would only consider inclusion if the same test as section 3.3.7.3 above was met in terms of medium or high risk of serious harm.

3.3.7.5 The AO must ensure that their assessment and authorisation clearly articulate legality, necessity and proportionality.

3.3.7.6 When considering proportionality, the AO must address the public benefit of using LFR and balance that benefit against the extent to which the Deployment engages individual rights and freedoms.

3.3.7.7 The AO must also be satisfied that LFR Operators and LFR Engagement Officers involved with the Deployment are appropriately trained, briefed and accountable, that equipment will be used correctly, and that those involved in the Deployment mitigate against inappropriate responses to LFR application Alerts.

3.3.8 The AO must also consider how the Deployment of LFR may impact on communities, and how the rights of everyone whose image is likely to be captured by the LFR application have been considered, and what safeguards are in place to protect them.

3.3.9 Deployment planning must consider whether members of the public have a practical and accessible alternative route around the Zone of Recognition. Where an alternative route is provided or identified, it must, so far as practicable, be accessible and must not disadvantage people with reduced mobility. This consideration must be reflected in the Community Impact Assessment, Equality Impact Assessment and operational planning.

3.3.10 EP and KP are not only concerned with developing and implementing precision policing tactics that protect the public as effectively as possible, but also ensuring that new tactics, such as LFR, are monitored for impact. EP and KP will implement a robust governance process to review the effectiveness and impact of LFR deployment. EP and KP will focus on delivering transparency and will achieve this by both responding to scrutiny as well as proactively engaging and involving a range of stakeholders, including people drawn from Essex and Kent communities as part of an ongoing process.

3.3.11 This guidance document will continue to evolve to reflect changes in legislation, regulation, technology and accepted use.

3.4 Strategic intention, objectives and use case

3.4.1 LFR Deployments must be run under a Written Authority Document that complies with the following strategic intentions and operational objectives.

3.4.2 LFR may only be deployed where the proposed deployment falls within an approved operational use case. Approved use cases are: prevention and detection of crime in identified crime hotspots; locating persons lawfully included on a watchlist who are reasonably believed to be present at the deployment location; protective security deployments at locations, events or premises where there is a relevant public safety purpose; and locating missing or vulnerable persons where strict necessity is established. LFR must not be deployed for general intelligence gathering, indiscriminate surveillance or speculative identification of members of the public.

3.5 Strategic intentions
EP and KP will:

3.5.1 use overt LFR technology responsibly and in accordance with common law policing powers and all applicable statutory safeguards. This includes targeting those wanted for criminal offences, those who pose a risk of harm, those wanted by the courts and, where strictly necessary and proportionate, members of the public who are at serious risk of harm.

3.5.2 comply with common law and statutory safeguards when discharging operational policing duties. LFR can assist EP and KP to protect life and property, preserve order, prevent threats to public security, prevent and detect crime, bring offenders to justice and uphold national security; and

3.5.3 strengthen and develop LFR technology capability to protect the public, reduce serious crime, to help safeguard vulnerable persons, and to keep Essex and Kent safe.

3.5.4 build public trust and confidence in the development, management, and use of LFR by taking account of privacy concerns and maximising transparency; and

3.5.5 maintain good governance through a command structure that incorporates strategic, operational, and technical leads for the deployment of LFR, with clear decision making and accountability; and

3.5.6 ensure that the deployment of LFR is used in compliance with all applicable legal requirements, and that it meets the oversight and regulatory framework as presently outlined in England & Wales by the Biometrics and Surveillance Camera Commissioner, the Information Commissioner and EP and KP LFR Documents; and

3.5.7 transparently identify, manage, and mitigate reputational and organisational risk to EP and KP; and

3.5.8 maintain public confidence by demonstrating that LFR is used responsibly, transparently and with effective oversight.

3.6 Operational objectives
EP and KP will: -

3.6.1 use LFR technology to enable EP and KP to discharge their common law policing powers. This includes the need to tackle our foremost operational priorities; and

3.6.2 adopt a robust and proportionate approach in engaging and pursuing individuals identified on an LFR Watchlist, using human decision-making. Officer oversight is active and involved, with the officer retaining full control and making the decision on whether to take action; and

3.6.3 engage with and provide reassurance to communities, listening and responding to concerns; and

3.6.4 continually identify and review risks relevant to the LFR technology, mitigate those risks, and maintain a response plan should mitigation fail.

3.7 Technological objectives
EP and KP will: -

3.7.1 ensure all LFR technology is fit-for-purpose and deployed effectively in line with strategic intentions and operational objectives; and

3.7.2 provide ongoing technical oversight and evaluation of the effectiveness of LFR as a policing tactic to help reduce violent crime and other imprisonable offences; and

3.7.3 keep technological capability, system performance and the EP and KP LFR SOP under review. Where appropriate, alternative facial recognition software or hardware may be tested or trialled. Any such trial must use comparable performance metrics to those gathered during operational LFR deployments so that findings can be assessed consistently. Existing retention periods and data protection safeguards will continue to apply.

3.8 Use of LFR

3.8.1 This guidance relates to the use of LFR in an overt capacity to help EP and KP protect the public. EP and KP will keep the use of LFR under review to ensure LFR continues to be used as an effective crime fighting tool.

3.8.2 LFR helps EP and KP use resources more efficiently. EP and KP consider that LFR can assist officers by rapidly comparing facial images against a defined Watchlist and presenting a Possible Match for human review, alongside information explaining why the person may be of policing interest.

3.8.3 The use of LFR also helps minimise information sharing, as LFR offers an alternative to social media campaigns or the sharing of information with external agencies. It is acknowledged that data protection considerations should not be treated as an absolute barrier to lawful and necessary information sharing.

3.8.4 Locations for the deployment of LFR will be kept under strict review, with LFR being deployed into areas where it has the greatest potential to assist EP and KP in discharging operational duties. The decision to deploy LFR will always be supported by a rationale that explains why a location was selected for LFR use in accordance with the principles set out in the Legal Mandate and other LFR Documents.

3.8.5 There must be a documented and objectively justifiable connection between the deployment location, the legitimate policing purpose and the persons included on the watchlist. The lower the seriousness of the offence or associated risk, the greater the justification required to demonstrate that deployment and watchlist inclusion are necessary and proportionate.

3.8.6 Given that LFR requires EP and KP personnel to review every Alert in real time for a decision on whether any further action is required, EP and KP will always deploy LFR in a way that is operationally effective and allows Alerts to be acted on as they are generated. LFR will not be used indiscriminately.

3.9 Overview of LFR deployment processes
End-to-end process

3.9.1 The end-to-end process of an LFR Deployment can be summarised as follows:-

3.9.1.1 LFR law enforcement purpose identified, safeguards considered, Deployment authorised, and Watchlist selected.

3.9.1.2 Notification of Deployment, and signage deployed. The public will be given five working days’ notice and engagement prior to deployment. Unless there is a significant operational reason for that period to be reduced.

3.9.1.3 As subjects pass an LFR camera, their faces are detected, and if the image quality is sufficient, they are compared against a Watchlist.

3.9.1.4 If a Possible Match is found in a Watchlist, the LFR application generates an Alert and both the detected face from the video and the Possible Match image from the Watchlist are presented to the LFR Operator / LFR Engagement Officer for human review.

3.9.1.5 The LFR Operator / LFR Engagement Officer will consider the Alert, noting the System, Subject and Environmental Factors, and together with the benefit of their experience and training, they will determine whether further action is required and whether the person is engaged.

3.9.1.6 An Alert generated by the LFR system does not establish identity, reasonable suspicion or grounds for arrest. Any engagement, stop, search, arrest or other operational action must be based on lawful and independent assessment by officers, taking account of all available information and relevant powers.

3.9.1.7 Cancellation of authority for the LFR Deployment and post-Deployment evaluation.

3.9.1.8 EP and KP LFR SOP provides a greater level of detail about the processes involved in the deployment of LFR by EP and KP. A flowchart summarising LFR deployment will be provided for front-line staff in due course.

Key points:

1. LFR uses images from people within the LFR Zone of Recognition. No individual is ‘targeted’ any more than another unless they are on a Watchlist.
2. the selection and placement of cameras is a vital consideration to ensure proper coverage of the desired area.
3. the quality and resolution of images (both those in the Watchlist and those from the video cameras) are of vital importance and must be carefully considered.
4. the inclusion of persons on a Watchlist needs to be justified based on the principles of necessity and proportionality.
5. it is important to balance the objectives of the operation with the size of the Watchlist and the available resource to respond to Alerts. If the objectives are too broad and/or the Watchlist is too large, the amount of resource required to respond to Alerts may be prohibitively high.

3.10 Policing LFR deployments effectively
3.10.1 There must be sufficient appropriately trained resource deployed to be able to respond to Alerts. This is important to ensure that the LFR application, and the data processed by it, is being effectively used.

3.10.2 The volume of people expected to pass through the LFR Zone of Recognition will influence the rate of False Negatives, False Alerts, Recognition Time, and the probability of people from the Watchlist being observed by the camera. These are all matters that must be considered when deciding what resources should be available.

3.10.3 It is vital that EP and KP are transparent in their use of LFR under this guidance. As well as using signage, the provision of sufficient policing resource will allow officers to answer questions that the public may have.

3.11 Governance, oversight and impact assessments
3.11.1 Following consultation the following stipulations have been proposed and accepted by EP and KP:

1. the overall benefits to the public must be balanced with public confidence of our use of LFR.
2. it can be evidenced that the technology itself will not result in unacceptable gender or racial accuracy variance into policing operations.
3. each deployment must be appropriately assessed and authorised, demonstrating both necessary and proportionate for a specific policing purpose.
4. LFR Operators are trained to understand the risks associated with use of the LFR application, including how potential injustices may be caused through inappropriate responses, and that they are accountable for their actions.
5. EP and KP will develop and maintain robust governance and oversight arrangements that balance the technological benefits of LFR with their potential intrusiveness. These arrangements will meet the Home Office Biometric Strategy’s requirement for transparency, whilst considering guidance from the Surveillance Camera and Biometric Commissioner. The arrangements will also focus on implementing a transparent and visible internal inspection, audit, and compliance enforcement regime.

3.12 Governance framework
EP and KP LFR documents address the stipulations detailed above. Governance and oversight of the use of the technology is approached in three stages, as follows:

1. pre-deployment
2. operational deployment
3. post-deployment

3.13 Pre-deployment

3.13.1 Authority to deploy LFR is an operational decision that must be granted by a trained and designated LFR Authorising Officer (AO), normally of Superintendent rank or above. The authority is not conferred by rank alone. LFR applications should be submitted and authorised through the agreed CAB/Charter process. Urgent out-of-hours requests should be referred to the on-call SCD Superintendent who is a trained AO, unless a different force-approved AO route is in place.

3.13.2 In exceptional urgency, where immediate authority is required and the usual AO route is unavailable, any interim decision must be recorded with full rationale and referred to a trained and designated AO as soon as practicable. The AO must then authorise continuation, vary the authority, or direct that the deployment must stop.

3.13.3 Prior to AO authorisation and the deployment of LFR in public spaces, several documents must be completed and an EP and KP officer of NPCC rank (or police staff equivalent) must be engaged by the AO. Whilst NPCC do not provide authority for LFR Deployment, consultation at this level exists to expose the proposed deployment to an elevated level of strategic thinking, whereby issues are taken into account as much as possible. This affords NPCC the opportunity to scrutinise the deployment and to ask the AO to consider what mitigation is required to address concerns at hand.

3.13.4 The AO must notify the Essex Police, Fire and Crime Commissioner, or designated staff member, and/or the Kent Police and Crime Commissioner, or designated staff member, prior to any Deployment where required by the relevant force governance arrangements.

3.13.5 The EP and KP Ethics Committees are independent sources of advice. Their terms of reference include providing advice and independent oversight on ethical matters and promoting ethical considerations within a legal and regulatory framework.

3.13.6 Several specific EP and KP documents and records need to be completed in support of each deployment. These are set out below:

EP and KP LFR deployment specific documents and records

LFR application	Sets out the details of a proposed deployment including location, dates/times, legitimate aim, legal basis, necessity, proportionality, safeguards, Watchlist composition, and resources.
Written authority document	The AO’s written authority provides a decision-making audit trail demonstrating how the AO has considered the legality, necessity, and proportionality of the deployment of LFR, the safeguards that apply and the alternatives that were considered but deemed to be less viable to realise the policing purpose. The written authority also details the arrangements that have been made to manage the retention and/or disposal of any personal data obtained because of the LFR Deployment. The written approval must be retained in accordance with MOPI and other relevant legislation or policy and be made available for independent inspection and review as required.
LFR deployment record	Records details of where and when a deployment was carried out, what resources were used, relevant statistics, outcomes and summary of any issues.
Assessments	These include the Community Impact Assessment, the Equality Impact Assessment, the Data Protection Impact Assessment, and the Biometrics and Surveillance Camera Commissioner’s Self-Assessment. These documents need to be considered by the decision-maker when authoring a deployment to ensure they are sufficient to address the issues arising from the proposed deployment. The decision-maker must ensure that issues have been adequately identified, documented, and mitigated by way of safeguards such that the deployment is not only necessary, but also proportionate to the policing purpose.
Deployment logs	Logs completed in the planning and execution of an LFR deployment. For example, logs completed by the Gold and Silver Commanders, LFR Operators and LFR Engagement Officers.