Policing faces: The present and future of intelligent facial surveillance

Lachlan Urquhart, Diana Miranda

Research output: Contribution to journalArticlepeer-review


In this paper, we discuss present and future uses of intelligent facial surveillance (IFS)in law enforcement. We do this through an empirical and legally focused case study of live automated facial recognition (LFR) in British policing. In Part I we analyse insights from 26 frontline police officers on LFR, exploring their concerns and scepticism about the technology.We contextualise this discussion on LFR deployment by examining current UK case law which raises concerns around human rights, data protection and anti-discrimination laws. In Part II,we turn our attention to future uses of IFS, examining frontline officer optimism around LFR when integrated with other surveillance technologies. We also discuss the emergence of new forms of IFS, namely emotional AI (EAI) technologies in law enforcement. We discuss how the law may impact this optimism and integration, by analysing the new EU Proposed AI Regulation (AIR)3. This law makes LFR a prohibited form of AI in the EU, whilst EAI use bylaw enforcement will be regulated as a high risk AI system (HRAIS), and thus subject to new rules and design requirements. Part III draws together our reflections on the legal issues and officer perspectives into a series of 10 lessons. These consolidate a set of practical issues we observe in deploying LFR and EAI. It highlights points that need attention for any future law enforcement use of IFS.
Original languageEnglish
JournalInformation and Communications Technology Law
Publication statusAccepted/In press - 13 Oct 2021


  • facial recognition
  • emotional AI
  • policing
  • surveillance


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