Crime and intelligence - Live Facial Recognition procedure (S5101)

1. Summary of change

2. What this procedure is about

3. Detail the procedure

3.16 In December 2020 the Surveillance Camera Commissioner (SCC) published his best practice guidance document ‘Facing the Camera’. The SCC advocated the need to ensure suitable controls exist around the placing of persons with protected characteristics on a Watchlist. Any controls, mitigations and processes identified by Kent Police and Essex Police in this document reflect the Kent Police and Essex Police LFR System’s performance and their particular use cases for LFR.

3.17 Kent Police and Essex Police have confidence in the LFR System’s performance, particularly in relation to gender, age and race. This has followed extensive academic and scientific studies of the algorithm to complement local and pre-procurement testing by the provider. In 2025, Cambridge University and the National Physical Laboratory (NPL) conducted studies to test the algorithm for bias, aiming to ensure the Chief Constable meets legal obligations under the public sector equality duty.

3.18 Kent Police and Essex Police recognise that regardless of performance considerations, particular care should be taken when considering and publishing details relating to (i) age including the protection of children – particularly the very young, (ii) disabled persons and (iii) those who have undertaken, or are undertaking, gender reassignment. This is because:

• There may be different privacy expectations around the use of LFR and that these can be particularly relevant in relation to these people given their potential vulnerability.
• Kent Police and Essex Police recognise that those involved in criminality have the wherewithal and capability to exploit information to their advantage. This may arise if there is a published performance differential that shows a lower performance level in relation to a particular protected characteristic.

3.19 Documenting composition: Kent Police and Essex Police provide that each Deployment must specifically identify and document whether the Watchlist contains persons who are believed or suspected to be:

For the purpose of this procedure, a relevant disability means any disability, impairment, condition or vulnerability recorded or reasonably believed to be relevant to the reliability, fairness, necessity or proportionality of LFR use, including matters that may affect identification, communication, mobility, engagement, safeguarding or the practical ability to avoid the Zone of Recognition.

• Aged under 18-years-old;
• Aged under 13-years-old;
• A person with a relevant disability;
• A person who has undertaken a gender reassignment and it is believed or suspected to be that the Watchlist would be using an image of that person taken prior to their reassignment.

Any use of an image of a child under the age of 13 would only be considered in high-risk cases.

3.20 The following outlines further, specific safeguards that apply to the composition of the watchlist:

Circumstances

Age (under 18)	Age (under 13)	Disability	Gender reassignment
LFR is used to locate a person under 18 and that person’s records state that person is aged (or suspected to be aged) under 18-years-old	LFR is used to locate a person under 18 and that person’s records state that person is aged (or suspected to be aged) under 13-years-old7	LFR is to be used to locate a person and that person’s records state that person has (or is suspected to have) a relevant disability	LFR is to be used to locate a person and that person’s records state that person has (or is suspected to have) (i) undertaken a gender reassignment and (ii) it is believed or suspected to be that the Watchlist would be using an image of that person taken prior to their reassignment

Safeguards

Necessity	Watchlist images	Legal advice	Technical advice
Specific regard needs to be had for the importance of locating the subject on a risk-based approach in line with Kent Police and Essex Police LFR Documents with a particular focus on ensuring the necessity case is fully made out.	There is a particular need to ensure that the image is a current as possible and of a suitable quality for inclusion on the Watchlist.	Specific advice must be sought from Legal Services and the relevant KP or EP LFR team prior to any seeking authorisation from an AO. Where authorisation is then sought, this advice needs to be provided to the AO to help inform their decision making and allow the AO to record their decision regarding any inclusion on the Watchlist and outline further safeguards that should apply.	Regard should also be had to consider System and Subject Factors and the ability for the LFR System to generate an accurate Alert against the image proposed for inclusion on the Watchlist.   Consideration should be given to the likely crowd flow / occlusion risk where shorter subjects may otherwise be blocked from the camera’s line of sight. Technical advice should be sought on a case-by-case basis to inform this assessment. Where authorisation is then sought, this advice needs to be provided to the AO to help inform their decision making and allow the AO to record their decision regarding any inclusion on the Watchlist and outline further safeguards that should apply.

3.21 Images that may be deemed appropriate for inclusion within an LFR watchlist include custody images of individuals and / or police originated images other than custody images of people who are:

• Wanted by the courts; and / or
• This term includes those with outstanding arrest warrants or who are otherwise required by the courts. The courts have already given consideration as to the necessity to locate this category of persons and given a direction that they should be apprehended. Such people pose a risk to the public at large.
• Suspected of having committed an offence, or reasonably suspected of being about to commit an offence; and / or
• Subject to bail conditions, court order or other restrictions that would be breached if they were at the location at the time of the deployment; and /or
• Missing persons categorised as ‘Medium Risk’ or ‘High Risk’
• As defined by Missing Persons Authorised Professional Practice as posing a risk of likely serious harm to themselves or others.
• The reference images are sourced from Athena, Missing person database (COMPACT) and Images provided by public with consent.

3.22 A decision to include ‘Medium Risk’ or ‘High Risk’ missing person on a watchlist should be made based upon current missing people of these risk levels only who have an affiliation to that area through residency or intelligence linking them to that area or local policing division. All images from the missing person database are checked to ensure that they are of sufficient quality to prevent any false positive alerts. All images are pre-assessed by the software to ensure they are of the correct levels of pixelation.

3.23 At immediate risk of serious harm and not locatable or contactable by any less intrusive means.

3.24 Intelligence suggests the person poses an immediate risk of serious harm to another person This refers to a person who has already been classified as High Risk through separate police assessment methods.

3.25 For a person to be included on the watchlist the Police must have a legal basis for action under a policing common law power.

3.26 The risk of harm will be informed by the intelligence case and/or the considerations set out in the applicable LFR form. This must inform the AO as to how the individual presents a risk of harm, or why they are likely to suffer harm, and:

• How using LFR to facilitate their location is necessary to manage the risk of harm identified; and
• Why the significance of the harm identified means it is necessary for the police to take action in order to manage the risk.

3.27 The applicant would also have to demonstrate the proportionality of any inclusion on a Watchlist. This would include considering:

• Any other less intrusive methods and whether they would be viable in the circumstance and what other, more intrusive methods would otherwise be necessary if the addition to the Watchlist is not made; and
• The importance of locating the person or people sought with reference to the threat, harm and risk which the addition to the Watchlist addresses;
• Whether the significance of the threat, harm and risk identified, which inclusion on the watchlist would address outweighs any expectations of privacy.

3.28 Where it is viable to do so without unduly impacting on the performance of the LFR System, suitable police-originated images should be preferred for inclusion on a Watchlist. However, there will be occasions, where no image is held by Kent Police, Essex Police or the wider law enforcement community, or if one is held, its quality or currency is not optimal for facial recognition purposes. In these circumstances, consideration may be given to the inclusion of a non-police originated image.

3.29 Non-police originated images are images which have not been taken by law enforcement. The expectations of privacy, and the intrusion associated with such images can vary depending on the nature of the image and to aid decision making and foreseeability, these have been attributed to three ‘layers of intrusiveness.

Image layer	Outline
Non-police originated image–Layer A	Non-police originated images where it is assessed that the public would expect the law enforcement to have access to them (but not including images obtained by covert means) with examples of criteria including: circumstances where images are readily available to the police through open-sources and/or the public have provided information to the police, including but not limited to appeals for information, imagery and footage; circumstances where the police have obtained the image as a result of a lawful power of search or seizure; data held by public bodies including where there are information sharing arrangements to support the regular sharing of data or explicit legal powers for information sharing.
Non-police originated image–Layer B	Images where it is assessed that they raise elevated expectations of privacy or where otherwise obtained covertly without the knowledge of the subject, including any imagery obtained pursuant to: the Regulation of Investigatory Powers Act 2000; and the Investigatory Powers Act 2016, Where the ability of relevant bodies to obtain such images is further supported and can be anticipated by reference to published Codes of Practice.
Non-police originated image–Layer C	Non-police originated images in circumstances where it is assessed that the public would not typically expect their image to be shared to, or accessed by the police at the point they provided it but there is nevertheless a lawful basis for the police to hold the imagery it has received. To help the public foresee where this may arise, this could include circumstances where the public have shared their image with a controller of data for an explicit purpose (be with a person, business, public body or other third party) and it was not in their contemplation at the time of sharing their image that it may be used for a law enforcement purpose. This would be particularly relevant where the controller promotes an approach to privacy which does not typically collaborate with UK law enforcement.

3.30 Any non-police originated image should only be included in a Watchlist with the authorisation of the AO where the necessity case is made out. The AO should consider all the circumstances relating to the image, including the layer of intrusiveness attributable to it and any relevant legal, privacy, operational or safeguarding factors. The AO may consult with the relevant Chief Officer in accordance with 3.5.8.

3.31 The types of non-police originated images that may be deemed appropriate for inclusion within an LFR watchlist are of people:

1. wanted by the courts; and/or
2. suspected of having committed, or where there are reasonable grounds to suspect that the individual depicted is about to commit an offence or where there are reasonable grounds to suspect an individual depicted to be committing an offence; and/or
3. subject to bail conditions, court order or other restrictions that would be breached if they were at the location at the time of the Deployment; and/or
4. missing persons assessed as presenting an increased risk; and/or
5. presenting a risk of harm to themselves or others; and/or
6. who are a victim of an offence, a person who the police have reasonable grounds to suspect that person would have information of importance and relevance to progress an investigation or is otherwise a close associate of an individual and that individual themselves would fall within paragraphs (a) – (d).
7. Reference images may be sourced from Athena, the missing person database (COMPACT), or images provided by members of the public with consent. Images provided with consent will often relate to missing people, but may also relate to serious crime investigations such as kidnap.

3.32 Kent Police and Essex Police LFR Documents

For each authorised LFR operation, the following assessments need to be created, reviewed, and amended where necessary by the relevant force: -

• Data Protection Impact Assessment* (Review/Amend/Adopt) *; and
• Equality Impact Assessment* (Review/Amend/Adopt) *; and
• Community Impact Assessment* (Review/Amend/Adopt) *; and
• The Surveillance Camera Commissioner’s Self-Assessment* (Review/Amend/Adopt) *;

Note: *Any assessment listed above showing `Review/Amend/Adopt’ has already been created by the relevant LFR team. Each will require a case-by-case consideration to ensure the document remains appropriate and sufficient for each LFR operation.

3.33 Management of Risk and Resources Levels

3.34.1 Each Deployment should be risk assessed in line with the relevant Kent Police or Essex Police procedure. The anticipated risk to officers and the public should be balanced against the overall intelligence picture, relevant factors linked to persons included on the Watchlist, the physical environment surrounding the Deployment, timing, community tension and any other relevant factors.

3.34.2 The level of resources, including back-up contingencies, required to support each Deployment is a matter to be determined by the operation’s command team.

3.34.3 Given the level of intrusion linked to the use of LFR for members of the public passing through the Zone of Recognition, and the processing of biometric data, it is vital that the command team ensure that sufficient resources are available to respond effectively to Alerts and to meet the law enforcement purpose of the LFR Deployment.

3.34.4 LFR System Engineers will be deployed to support LFR Deployments where required.

3.34.5 All Kent Police and Essex Police officers and staff deployed on LFR Deployments must be compliant and in date with relevant first aid and, where applicable, officer safety training requirements. All officers and staff involved in an LFR Deployment must receive LFR training prior to deployment, unless they have received comparable training delivered by another UK police force.

3.34.6 As part of the application process, the applicant should consult with the relevant force LFR team and/or Covert Authority Bureau, as applicable, to determine the appropriateness and viability of a deployment. This should be done before the application is submitted to the AO.

3.35 Cameras and camera placement

3.35.1 Cameras must be selected so that the image resolution, framerate, field-of-view and low-level light performance can provide images of sufficient quality for use in the facial recognition application. Current FR systems typically require a facial image with no less than 100 pixels between the centres of the subject’s eyes (Inter-Eye Distance or IED). The FR vendor should advise on specific requirements for their system.

3.35.2 Unless the environment is well controlled, cameras must be capable of operating at Wide Dynamic Range in order to generate high quality images under a variety of lighting conditions.

3.35.3 Cameras should ideally be positioned to capture faces as close as possible to the ‘face-on’ condition, similar to a passport image. This typically requires the cameras to be much lower than is normally the case for existing CCTV. Camera placement and angle should be further considered where those sought may be more likely to be occluded in a busy crowd in order to maximise the prospects of location.

3.35.4 Ideally the environment should be managed such that every face is evenly illuminated. Highly directional lighting, for example strong sunlight, should be avoided, which may require consideration of how the lighting will change throughout the day.

3.35.5 In general, the Zone of Recognition will be smaller than the field of view of the camera; for example, not all faces in the field of view may be in focus and not every face in the field of view will be imaged with the minimum necessary Inter-Eye Distance (IED).

3.35.6 A typical 2MP camera will provide sufficient resolution for LFR to work on a maximum of 3 to 4 people side by side. Therefore, consideration needs to be given to camera location and the physical environment. For example, looking for opportunities to funnel or restrict the movement of people within the Zone of Recognition. However, if the flow is reduced beyond a certain level, individuals may be grouped very close together, occluding or partly occluding the faces of people (people behind people).

3.35.7 Detection and processing of faces is an intensive task for a computer system. The supplier of LFR software should provide guidance on hardware requirements and the number of faces that can be simultaneously processed from within a single frame. If the system is set to process too many faces, this will potentially result in delays to the LFR system response. It may also result in missed Alerts due to ‘dropped frames’ where the software skips some of the video footage in an attempt to catch up.

3.36 LFR operational roles

LFR Command Team

3.36.1 LFR Deployments must be supported with a clear command structure. The following roles are defined for the purpose of creating an appropriate hierarchical command structure: -

• Gold Commander (Superintendent or above); There is only one Gold Commander for any LFR Deployment. Gold has strategic command of the operation and must ensure that their `strategic intention’ aligns with the Written Authority Document. Gold maintains overall responsibility for ensuring that the use of LFR remains lawful, necessary and proportionate. Gold will also liaise as necessary with NPCC ranked officers. Gold can also perform the AO role.
• Silver Commander (Chief Inspector or above); There is only one Silver Commander for any LFR Deployment. Silver reports to Gold. Silver has tactical command of the Deployment and is responsible for tactical implementation. This officer has absolute authority to suspend or terminate the Deployment at their discretion. They are also responsible for ensuring that the use of LFR and their tactical implementation remains lawful, necessary and proportionate throughout the duration of the Deployment, having particular regard to the effectiveness of the safeguards in place whilst LFR is being used.
• Bronze Commander (Sergeant or above); Bronze Commanders are assigned operational command responsibilities by Silver. Bronze Commanders report to Silver. Bronze Commanders should be present at Deployment locations unless otherwise directed by Silver. There may be more than one Bronze Commander subject to requirements set by Silver. Where this is the case, Silver must document command responsibilities and protocols with sufficient clarity and ensure that they are fully understood by all officers and staff involved in the Deployment.

3.36.2 Where LFR Deployments form part of a larger overarching policing operation, the terms Gold, Silver and Bronze (as described above) may be substituted for alternative command team terminology or be subsumed into a larger command structure as necessary and appropriate for the effective delivery of the overarching policing operation.

3.37 LFR operator

3.37.1 LFR Operators receive detailed training prior to being deployed operationally. Their role is to monitor and assess application Alerts, before working with LFR Engagement Officers (as necessary) to decide whether an Engagement is required.

3.37.2 The LFR Operator must log all Alerts to help facilitate and support command team reviews during the Deployment, and those that take place post-Deployment. The LFR Operator must flag any concerns they have regarding LFR System performance to the Silver Commander.

3.37.3 The LFR Operator’s log should include: -

• The LFR Operator’s assessment of each Alert as part of their assistance to the Engagement Officer when Adjudicating over Alerts prior to making any decision to Engage; and
• what decision was taken regarding whether to Engage a member of the public or not; and
• whether an Engagement was successfully undertaken, and the outcome of the Engagement.

3.38 LFR Engagement Officer

3.38.1 LFR Engagement Officers must have an understanding of the LFR application, how it performs, and what effect Subject, System, and Environmental Factors might have. These officers must receive a full operational briefing prior to deployment. These officers will be deployed in uniform.

3.38.2 When conducting an Engagement, LFR Engagement Officers must ensure that they do so lawfully, and in an appropriate and proportionate manner. Officers must comply with the Code of Ethics at all times. Wherever possible, members of the public who have been subject of an Engagement, should be supplied with an LFR information leaflet.

3.38.3 The LFR Operator may be supportive of an engagement taking place, but in any case, it is always for an LFR Engagement Officer to make their own final decision on whether an Engagement should take place. It must not be an automatic consequence that an Alert results in an Engagement. In making their decisions, LFR Engagement Officers must give due regard to the likelihood of Subject, System, or Environmental Factors influencing the generation of an Alert.

3.38.4 When an engagement is initiated, it is for the officers involved to investigate the identity of the person engaged using appropriate and lawful means at their disposal. There is a four-stage process leading to an appropriate outcome.

STAGE 1 – LFR software alerts to a potential match on the watchlist. LFR operator will visually assess the two images and only notify an engagement officer if they believe the match is correct.
STAGE 2 – Engagement officer will approach the individual and confirm their identity via personal documentation or fingerprint device if appropriate.
STAGE 3 – Engagement officer will then assess and decide on the appropriate form of disposal.
STAGE 4 – If an arrest takes place, then the appropriate custody department and the officer in the case will be notified.

3.38.5 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 a lawful and independent assessment by officers, taking account of all available information and relevant powers. Officers must always seek to make sufficient additional enquiries to satisfy themselves of their grounds to arrest or detain. Where confronted with a non-compliant subject, and the circumstances are such that an officer has an honestly held belief they must use their powers of arrest or detention before further checks have been possible, further checks must be made as soon as reasonably practicable so that the decision is reviewed without unnecessary delay.

3.38.6 If an ‘Engaged Individual’ cannot be identified or fails to confirm their identity, this alone does not constitute a criminal offence and does not necessarily render them liable to arrest. Officers must be in a position to justify the use of any powers, any action taken, and have a lawful basis for doing so.

3.38.7 After any Engagement (that follows an Alert), the LFR Engagement Officer must update the LFR Operator with the outcome of that Engagement.

3.38.8 Where members of the public choose to exercise their right to avoid an LFR Zone of Recognition, officers are reminded that this is not an offence. The police have no legal powers to direct or compel members of the public to enter a Zone of Recognition. None of this means that LFR Engagement Officers, or other officers involved in an ancillary role linked to an LFR Deployment, cannot or should not engage with a member of the public as they would do in any other set of circumstances where someone’s behaviour or presence gives rise to suspicion or the use of any other policing power where it is right and proper to do so. If other lawful orders are in existence where there is a requirement to remove face coverings (i.e. Sec 60) then the silver commander will direct officers deployed accordingly in line with the legal direction. There are no common powers to require someone to remove a face covering outside specific legislation.

3.39 LFR System Engineers

3.39.1 LFR System Engineers have enhanced technical training for the Deployment of LFR, see Kent Police and Essex Police LFR Policy Document for further information. LFR System Engineers are responsible for the set-up of the LFR equipment and the optimisation of the LFR application to maximise performance.

3.40 Public Engagement

3.40.1 Public engagement must be supported using online resources available to the public, which should be underpinned by a press and media strategy giving advance notice of deployments. At and around the location of deployments, notices providing information, including details of the Privacy Notice, should be distributed and feedback via email should be sought.

3.40.2 Operational briefings delivered to officers and stakeholders prior to deployments should promote openness with the public and transparency about the use of LFR. Officers should be encouraged to engage with the public to increase awareness of how LFR helps keep the public safe and how it helps bring offenders to justice. It is also helpful for officers to be in possession of information leaflets that can be handed out to the public. Such information leaflets should deliver important key messages aimed at promoting trust and confidence through improved understanding.

3.40.3 Key stakeholders, including the PCC’s Office, may be invited to observe the planning and deployment of LFR although it must be noted that the deployment is an operational matter.

3.40.4 In advance of deployments Kent Police and Essex Police will ensure that:

1. LFR Deployments are notified to the public using Kent Police and Essex Police websites and other appropriate communication channels, including social media; and
2. LFR awareness raising measures, such as signs and/or leaflets, are prepared to support LFR deployment in line with the Kent Police and Essex Police LFR SOP; and
3. literature is prepared for persons who may be engaged (to include information outlined within a privacy notice); and
4. Officers are briefed on their powers and the limits thereof. In particular, it must be made clear that there is no power to require an individual’s cooperation in having their image captured, unless either the threshold for arrest has been reached, or an Inspector or above has authorised the exercise of the power under section 60AA of the Criminal Justice and Public Order Act 1994 for a Constable in uniform to compel a person to remove anything that conceals their identity; and
5. External engagement is considered in discussion with the relevant Kent Police or Essex Police LFR team. It may be appropriate to pursue engagement opportunities with several stakeholders, including local authorities, and public consultative or ethical review bodies. It is important that engagement is coordinated and so the relevant LFR team must be consulted prior to this kind of activity.

3.40.5 During deployments Kent Police and Essex Police will ensure that:

1. awareness raising measures are used in line with the Kent Police and Essex Police LFR SOP to ensure that the policing presence is overt such that the public can establish that LFR is being used and understand the nature of the data being processed; and
2. notices with a brief explanation and reference to Kent Police and Essex Police websites are available to hand out to the public on request; and
3. information is offered to persons engaged by officers in accordance with the policy referred to above.

3.40.6 After deployments Kent Police and Essex Police ensure that:

1. information about the deployment, including location, time, date, number of alerts, engagements, arrests, and any other information considered helpful and suitable for disclosure, is published on Kent Police and Essex Police websites. Care must be taken to ensure that no personal data is published;
2. external engagement is considered in discussion with the relevant Kent Police or Essex Police LFR team. Again, it may be appropriate to pursue engagement opportunities with several stakeholders, including local authorities, and public consultative or ethical review bodies. It is important that the engagement is coordinated and so the relevant LFR team must be consulted prior to this kind of activity; and
3. engagement with representatives from the Information Commissioners Office will be ongoing.

3.40.7 Post-Deployment

1. Following each LFR Deployment, the Silver Commander must ensure that a post Deployment evaluation is completed which is updated in the Deployment Record. The evaluation process must capture an assessment of the operational effectiveness of the LFR Deployment. This evaluation should be both qualitative and quantitative in nature.
2. The evaluation should clearly articulate what measures are used to assess effectiveness and what benchmarking criteria are used. It should also assess the effectiveness of the safeguards used for the Deployment and what opportunities exist to improve them for future use, and how learning will be shared.

The evaluation may include as many measures as appear appropriate, but as a minimum must include the following metrics (including what methods were used to obtain them): -

• total number of individuals and the total number of images included in the Watchlist (there may be multiple images of some individuals); and
• total number of facial images detected in the video stream that were of sufficient quality for searching against the Watchlist (i.e. the LFR application was able to generate a Template from them); and
• total number of LFR application-generated Alerts; and
• total number of Alerts that do not result in an Engagement; and
• total number of Alerts where a decision was taken to Engage an individual; and
• total number of Alerts that are confirmed as true alert (the individual is who the LFR application suggests are); and
• total number of Alerts that are confirmed as a false alert (the individual is not who the LFR application suggests they are); and
• total number of correct Alerts that result in an Engagement that do not require any further police action; and
• outcome of each case where police action is instigated following an Alert; and
• number of people Engaged, where the Engagement was not the result of Alert, including the reasons and outcome; and
• Threshold setting for the Deployment.
• OPC complete the alerts spreadsheet which includes full details of the individual including their age, sex and ethnicity. The outcome of the alert i.e. arrest and the disposal.

3.41 LFR Application Security

3.41.1 The LFR application, associated equipment and deployment data must be protected by appropriate physical, technical, access-control, audit and data-security arrangements approved by the relevant force. Detailed technical security arrangements must not be published in this procedure where disclosure could undermine operational or information security.

3.41.2 Any loss, theft, compromise or suspected compromise of LFR hardware, software, removable media, access credentials or deployment data must be reported immediately to the AO, Gold Commander and the relevant Data Protection Officer, and managed in accordance with force information-security and data-breach procedures.

3.42 Data Retention and Data Management

3.42.1 Kent Police and Essex Police must ensure that the processing of any data associated with LFR is conducted lawfully and in compliance with the Kent Police and Essex Police LFR documents. This means that: -

• where the LFR application does not generate an Alert, that a person’s biometric data is immediately automatically deleted; and
• live operational watchlist data and any medium used to import the Watchlist must be deleted as soon as practicable, and in any case within 24 hours following the conclusion of the Deployment.

3.42.2 The audit record, search rationale, decision-making material used to compile the Watchlist, deployment logs and records required for scrutiny, review, complaints, disclosure or legal challenge will be retained securely in accordance with MOPI, CPIA, data protection requirements and relevant force retention policies. Any personal data retained for evaluation, complaint, conduct, disclosure or legal purposes must be documented, justified and retained only for as long as necessary.

3.42.3 All CCTV footage generated from LFR Deployments is deleted within 31 days, except where retained: -

• in accordance with the Data Protection Act 2018, MOPI and the Criminal Procedures and Investigations Act 1996; and /or
• in accordance with Kent Police and Essex Police complaints / conduct investigation policies.

3.42.4 To support compliance the LFR application has a full audit capability, and the LFR Operator and LFR Engagement Officer log is retained in line with MOPI retention periods.

3.42.5 The loss or theft of any LFR hardware, including a laptop, mobile device or camera, or other data, irrespective of whether protected by encryption, must be reported immediately to the AO, Gold, and the relevant Kent Police or Essex Police Data Protection Officer.

3.43 Register of Deployments

3.43.1 Any Deployment of LFR must be recorded on a centrally held register. This register will record a number of things including: -

• Name and rank of the AO and command team; and
• Date, time, duration, and locality of Deployment; and
• Watchlist composition statistics (not including any personal data); and
• The number of Alerts and the various statistics relating to these; and
• Number of Engagements and their results.

3.43.2 Kent Police and Essex Police will make information relating to LFR Deployments available to the public in accordance with the Kent Police and Essex Police LFR Documents.

3.44 Contact Information

3.44.1 The relevant Kent Police or Essex Police LFR team should be contacted for deployment advice, operational support and governance enquiries.

3.45 Governance & Oversight

3.45.1 The following stipulations are accepted by Kent Police and Essex Police:

• The overall benefits to the public must be balanced with public confidence of our use of LFR.
• It can be evidenced that the technology itself will not result in unacceptable gender or racial accuracy variance into policing operations.
• Each deployment must be appropriately assessed and authorised, demonstrating both necessary and proportionate for a specific policing purpose.
• 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.
• Kent Police and Essex Police will develop and maintain robust governance and oversight arrangements that balance the technological benefits of LFR with its potential intrusiveness. These arrangements will meet national requirements for transparency, whilst considering guidance from relevant regulators and national policing bodies. The arrangements will also focus on implementing a transparent and visible internal inspection, audit and compliance enforcement regime.
• A quarterly review of the positive alerts will take place analysing the performance of the deployments and the analysis of the special characteristics of the individuals subject to alert i.e. a breakdown of age, gender, ethnicity together with arrest and disposal outcomes.

3.45.2 Governance and oversight of the use of the technology is approached in the three stages below:

• Pre-deployment
• Operational deployment
  Post-deployment

3.45.3 Pre-deployment:

• Authority to deploy LFR is an operational one, where the Authorising Officer (AO) rank is set at Superintendent. In exceptional cases of urgency, an officer below the rank of Superintendent, but not below the rank of Inspector, may authorise the deployment of LFR.
• Where an officer below the rank of Superintendent provides the authority, a Superintendent must be informed as soon as practicable. It is for the Superintendent to then authorise the deployment to continue, making changes to the authority where they believe necessary, or direct that it must stop.
• Prior to AO authorisation and the deployment of LFR in public spaces, several documents must be completed and the relevant Chief Officer lead for Kent Police or Essex Police must be made aware by the AO. Whilst the Chief Officer does not provide authority for LFR deployment, consultation at this level exists to expose the proposed deployment to an elevated level of strategic thinking in line with the circumstances described at 3.5.8, whereby issues are considered as much as possible. This affords the Chief Officer the opportunity to scrutinise the deployment and to ask the AO to consider what mitigation is required to address concerns at hand.
• Several specific Essex Police documents and records need to be completed in support of each deployment. These are set out below:

Kent Police and Essex Police 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 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.

3.46 Several other specific Kent Police and Essex Police documents pertaining to each LFR deployment have been completed centrally. These are set out below:

Kent Police and Essex Police LFR Documents and Records

Kent Police and Essex Police Data Processing – Appropriate Policy Documents Documents	Kent Police and Essex Police policy on the processing of data pursuant to the Data Protection Act 2018 and UK General Data Protection Regulation relating to LFR.
Kent Police and Essex Police Legal Mandate	Outlines the legal considerations to be addressed to use LFR.
Kent Police and Essex Police Training	Provides the necessary training to ensure those involved in authorising and deploying LFR are familiar and implement the considerations relevant to its lawful, ethical and appropriate use.

3.47 Oversight bodies and Regulatory Framework

3.47.1 Within Kent Police and Essex Police, senior internal oversight for LFR will be provided through the relevant force governance arrangements. External oversight and scrutiny may also be provided through the relevant Police and Crime Commissioner’s Office.

3.47.2 The Kent Police and Essex Police LFR Legal Mandate sets out the legal framework for the use of LFR technology, whilst the LFR Policy Document and this procedure document support implementation. The legal framework includes relevant case law, including Bridges and R (Thompson and Carlo) v Commissioner of Police of the Metropolis [2026] EWHC 915 (Admin), which confirms the importance of clear, foreseeable and constrained policies with appropriate safeguards and oversight.

3.47.3 Nationally, the `NPCC Facial Recognition Technology Board’ provides oversight for the operational uses of facial recognition within UK Law Enforcement.

3.47.4 Further oversight opportunities may arise in relation to the `Joint National Biometric Strategic Board’. This is co-chaired by the NPCC and the Home Office Data and Identity Department, and involves representatives of the Information Commissioners Office, the Surveillance Camera Commissioner, the Biometric Commissioner and the Essex Data Ethics Committee. More detail on these roles:

• Surveillance Camera Commissioner (SCC); The role of the Surveillance Camera Commissioner is to encourage compliance with the surveillance camera code of practice, review how the code is working, provide advice to ministers on whether the code required amendment. Any Kent Police or Essex Police LFR system will need to comply with this Code and the twelve guiding principles. This guidance document seeks to apply those principles. See www.gov.uk/government/organisations/surveillance-camera-commissioner
• Biometrics Commissioner (BC); The Commissioner is independent of Government and aims to keep the police use and retention of biometric data under review. The Commissioner makes decisions on applications made by the police to retain DNA profiles and fingerprints, and reviews national security determinations that are made or renewed by the Police in connection with the retention of DNA profiles and fingerprints. The Commissioner also reports to the Home Secretary about the carrying out of their functions. See: www.gov.uk/government/organisations/biometrics-commissioner
• Information Commissioner’s Office (ICO); The ICO upholds information rights in the public interest, promoting openness by public bodies and data privacy for individuals. The Data Protection Impact Assessment must comply with Sections 35 – 40, (Principles 1 – 6) and Section 64 Data Protection Act 2018 and should be shared with the ICO. See www.gov.uk/government/organisations/information-commissioners-office
• Relevant ethics and scrutiny bodies may provide independent advice and oversight to Kent Police and Essex Police on ethical matters, including the promotion of ethical considerations within a legal and regulatory framework.

4. Equality Impact Assessment (EIA)

EIA - September 2026.

5. Risk assessment

5.1 Each Deployment should be risk assessed in line with the relevant Kent Police or Essex Police procedure. The anticipated risk to officers and the public should be balanced against the overall intelligence picture, relevant factors linked to persons included on the Watchlist, the physical environment surrounding the Deployment, timing, community tension and any other factors that appear relevant.
5.2 The level of resources, including back-up contingencies, required to support each Deployment is a matter to be determined by the operation’s command team.

5.3 Given the level of intrusion linked to the use of LFR for members of the public passing through the Zone of Recognition, and the processing of biometric data, it is vital that the command team ensure that sufficient resources are available to respond effectively to Alerts and to meet the law enforcement purpose of the LFR Deployment.

5.4 LFR System Engineers will be deployed to support LFR Deployments where required.

5.5 All Kent Police and Essex Police officers and staff deployed on LFR Deployments must be compliant and in date with relevant first aid and, where applicable, officer safety training requirements. All officers and staff involved in an LFR Deployment must receive LFR training prior to being deployed.

6. Consultation

6.1 The following internal and external stakeholders should be consulted during the formulation, approval and review of this document:

• Unison
• Police Federation
• Essex Diversity and Inclusion Team
• Health & Safety
• Head of Operational Change
• PSD D/Superintendent
• Risk
• Policy
• Superintendents Association
• Strategic Force Crime & Incident Registrar
• DPO/Temp Head of Info Management
• Head of Operational HR
• Support Network Chairs and Vice Chairs
• Specials Command Essex
• Essex Diversity and Inclusion Team
• Head of Continuous Improvement
• Head of the Control Centre
• Legal
• Kent Force Independent Advisory Group (IAG)

7. Monitoring and review

7.1 Kent Police and Essex Police will carry out intermittent reviews for legislative, regulatory or process changes and will carry out yearly reviews of the whole document.

8. Governing force policy
Related force police or related procedures

8.1 Data Security

8.1.1 Kent Police and Essex Police have measures in place to protect the security of data in accordance with their respective Information Management policies.

8.2 Retention & Disposal of Records

8.2.1 Kent Police and Essex Police will hold data in accordance with their respective records review, retention and disposal policies.

8.2.2 Data will only be held for as long as necessary for the purposes for which it was collected. Victims and members of the public should be reminded that Kent Police and Essex Police take the protection of personal data seriously as described in their respective privacy notices.

9. Other source documents, e.g. legislation, APP, partnership agreements (if applicable)

9.1 Further documentation is available providing useful information relevant to LFR. This is detailed below.

• Information Management APP; https://www.college.police.uk/app/information-management
• National Decision Model; National decision model | College of Policing
• National Intelligence Management; Intelligence management | College of Policing
• College of Policing Code of Ethics
• Home Office Biometric Strategy – Published June 2018; www.gov.uk/government/publications/home-office-biometrics-strategy
• High Court Ruling – R (on the application of Edward Bridges) v The Chief Constable of South Wales [2019] EWHC 2341 (Admin)