‘Ethical facial recognition’

May 28, 2025

New standards for a sensitive technology

Facial recognition technology (FRT) has long been more than just a technical buzzword – it is well on its way to becoming an integral part of modern security architectures. In hospitals, airports, retail outlets and educational institutions, more and more operators are relying on biometric systems for access control and surveillance. However, as the technology becomes more widespread, so too does the responsibility – legally, ethically and operationally.
A new British standard is now set to provide clarity: BS 9347:2024, ‘Facial recognition technology: Ethical use and deployment in video surveillance-based systems – Code of practice’, defines for the first time a structured framework for the responsible integration of facial recognition into surveillance systems.

From technician to trusted partner

For installers and integrators, the new standard marks a turning point. It requires not only technical expertise, but also a sense of ethical responsibility. Mike Isherwood, Managing Director of System Q* and a long-standing industry expert, sums it up in an interview with the British trade magazine Benchmark: ‘I believe that this standard is more than just a guideline – it is an invitation to the industry to show that we are not just installing technology, but also taking responsibility.’

More than a set of rules – an ethical compass

The BS 9347:2024 standard is based on six guiding principles:

  • Governance and accountability: Clear responsibilities and monitoring
  • Human oversight: Decision-making processes with human involvement
  • Data protection and data management: Protection of sensitive information
  • Technical robustness: Ensuring reliability and security
  • Transparency and explainability: Traceable systems and communication
  • Fairness and anti-discrimination: Recognising and preventing bias

These principles are not a checklist that can simply be ticked off – they form the foundation for trust, legal certainty and long-term success.

Check necessity – before installation

Before any implementation, BS 9347:2024 recommends a thorough needs analysis. Installers and security experts should work with their customers to clarify whether the use of facial recognition is really necessary or whether other solutions would serve the purpose just as well. The decision tree in Figure 3 of the standard serves as a guide – a helpful tool for structuring such discussions.

Data protection is not optional

Another often underestimated point is the legally required data protection impact assessment (DPIA). Mike Isherwood warns:
‘Anyone who starts an FRT project without a DPIA is not only acting negligently – they are putting their company in legal trouble.’

Technology with responsibility

Ethical use begins with choosing the right technology. Solutions from System Q, for example, focus on fairness and transparency. The algorithms used are trained on diverse data sets to minimise bias. They also feature human-in-the-loop (HITL) functions, as expressly recommended by BS 9347:2024. Tested under various lighting conditions and supported by a British compliance team, these systems meet high quality standards.

Data protection ‘by design’

Installers play a key role in ensuring that the system is configured in accordance with data protection regulations. This includes, for example

  • Setting similarity thresholds
  • Logging user actions
  • Automating data deletion routines
  • Implementing clear, legally compliant signage

Only through this interaction can a system be created that not only works but also meets social expectations.

Governance – more than just good intentions

Organisational aspects are also part of the ethical use of FRT. Customers need support in introducing robust governance structures – from appointing a responsible person (SAP) to documenting human system interventions and conducting regular system reviews. Installers are important advisors here.

Training creates security

Knowledge is at least as important as technology and processes. Comprehensive training should therefore be standard, covering topics such as:

  • legal requirements (e.g. GDPR)
  • detection and reduction of system distortions
  • correct use of FRT
  • documentation and audit standards

“Well-trained customers are not only more legally secure – they also appreciate the advisory role of the installer more,’ explains Mike.

Legal expertise as a competitive advantage

BS 9347:2024 is embedded in a complex legal environment. Data protection (UK GDPR), the Human Rights Act 1998, the Equality Act 2010 and the Surveillance Camera Code of Practice together form the legal foundation for the use of facial recognition. Those who are confident in navigating these requirements demonstrate professional competence – and build trust. Mike Isherwood emphasises: ‘The ability to correctly classify legal overlaps sets you apart from the competition and makes you a sought-after expert.’

Support from System Q

System Q offers comprehensive support for installers who want to comply with BS 9347:2024. This includes:

  • Preconfigured templates for standard compliance
  • Technical support tailored to UK regulations
  • Regular software updates to reduce distortion
  • Templates for easy integration into customer processes

Conclusion: Trust as a factor for success

In a world where trust must be earned rather than taken for granted, ethical use of technology is not an option – it is a duty. Installers who embrace this responsibility have the opportunity to position themselves as reliable, forward-thinking partners. There has never been a better time to set yourself apart from the competition through integrity and expertise.
*systemq.com/frt-compliance-guide

Summary

Facial recognition technology (FRT) is on the rise – but its use requires clear ethical and legal guidelines. The new British standard BS 9347:2024 establishes a binding framework for responsible use in surveillance systems for the first time, with six principles including data protection, transparency and fairness. For installers, this means that they must not only be technically proficient, but also act in an advisory and ethical manner. This includes needs analyses, data protection impact assessments, governance processes and customer training. The aim is to build trust and make FRT systems legally compliant, transparent and non-discriminatory.

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