With growing interest in AI-powered surveillance, facial recognition technology (FRT) is fast becoming a mainstream addition to modern security ecosystems. From hospitals and airports to retail and education, more end users are exploring the benefits of biometric access and surveillance. But as powerful as it is, FRT comes with significant legal, ethical and operational responsibilities.
The new British Standard BS 9347:2024, “Facial recognition technology: Ethical use and deployment in video surveillance-based systems – Code of practice” sets clear guidelines for the ethical implementation of facial recognition technology in video surveillance-based systems.
For installers and integrators in the UK, the introduction of BS 9347:2024 sets a new benchmark for responsible deployment, offering a clear framework to reinforce trust, transparency and legal compliance.
Talking to Benchmark, Mike Isherwood, Managing Director of System Q, who has worked closely with installers nationwide, shares his firm belief in the potential of this standard to reshape the role of security professionals. “I believe this standard is more than a regulation. It’s an invitation: an opportunity for professionals to prove they’re not just technicians, but trusted ethical partners.”
Understanding BS 9347:2024: More Than a Checklist
BS 9347:2024 is the UK’s new code of practice for the ethical deployment of FRT. It outlines six guiding principles: Governance and accountability: Ensure clear responsibility and oversight
- Human agency and oversight: Maintain human involvement in decision-making
- Privacy and data governance: Protect personal information
- Technical robustness and safety: Ensure system reliability and security
- Transparency and explainability: Provide clear information about system operation
- Diversity, non-discrimination and fairness: Prevent bias and discrimination
The first step is a thorough needs assessment. Before an installation begins, security professionals should work with clients to assess whether FRT is genuinely necessary or if less intrusive solutions might better meet their security needs. The decision tree process in Figure 3 of BS 9347:2024 can help structure these discussions.
Mike also says, “You should always remind your clients that Data Protection Impact Assessment (DPIA) is legally required under UK GDPR, and that failure to carry one out could have serious consequences for them and their business, should they move ahead with an FRT-based solution.”
Choosing the right technology is equally critical. Ethical deployment starts with ethical systems. System Q’s facial recognition offerings, for instance, prioritise fairness and transparency, with algorithms trained on diverse datasets to minimise bias and human-in-the-loop (HITL) functionality built in, as recommended by BS 9347:2024. These systems are rigorously tested across varied lighting conditions and supported by UK-based compliance expertise.
Privacy by design should also be a fundamental part of any installation plan. Installers have a vital role in helping clients configure their systems to enhance privacy protections, including setting appropriate similarity thresholds, ensuring operator actions are logged for accountability, automating data deletion policies, and using clear, compliant signage.
Another key step is helping clients establish clear governance procedures. Identifying a Senior Accountable Person (SAP), documenting processes for human verification, setting up quarterly review processes, and recording how data subject access requests are handled are all practical steps installers can guide their clients through to ensure a more robust, ethical operation.
Laso, training cannot be overlooked. Comprehensive client education should cover legal responsibilities under GDPR and related regulations, recognition and mitigation of system bias, correct use of FRT systems, and maintenance of proper documentation and audit procedures. As Mike points out, this empowers clients and reinforces the installer’s role as a trusted advisor.
Navigating Legal Complexity
BS 9347:2024 does not exist in isolation. Security professionals must also be fluent in wider legal frameworks to offer meaningful guidance. UK GDPR, the Human Rights Act 1998, the Equality Act 2010, and the Surveillance Camera Code of Practice all intersect with ethical facial recognition deployment.
Being able to weave these considerations into project discussions not only ensures compliance but positions installers as genuine experts in the field. As Mike highlights, “Being fluent in these overlapping regulations will add real value to your service, and allow you to demonstrate expertise and mark your company out as a trusted voice in the field.”
System Q supports this commitment to ethical practice by providing tools that ease the compliance process. Their FRT solutions offer pre-configured templates that align with BS 9347:2024, technical support tailored to the UK regulatory environment, regular updates addressing bias and security concerns, and documentation templates that streamline client onboarding.
In a landscape where public trust must be earned, not assumed, ethical deployment of facial recognition technology is no longer optional. It’s essential. And for those installers ready to lead the way, the opportunity to become a vital, trusted partner has never been clearer.
For more practical information and guidance on FRT compliance, visit systemq.com/frt-compliance-guide.