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Amnesty International has strongly criticised Police Scotland’s decision to proceed with the use of live facial recognition (LFR) technology, describing it as a “mode of mass surveillance” that poses a “grave threat to the rights and freedoms of the Scottish public.”
In a letter sent to Chief Constable Jo Farrell and Scottish Police Authority (SPA) Chair Fiona McQueen CBE, Amnesty urged both bodies to reconsider the move, warning that the adoption of LFR “would represent a fundamental and historic shift in the relationship between Police Scotland and the public.”
Amnesty argued that live facial recognition is inherently incompatible with Scotland’s international human rights obligations, citing risks to privacy, equality and freedom of peaceful assembly. The organisation said the technology involves “widespread and bulk monitoring, collection, storage and analysis of biometric data without consent or reasonable suspicion.”
“Facial recognition technology is a mode of mass surveillance both by design and in its deployment,” the letter stated. “It erodes civic spaces and significantly hampers the right to peaceful protest, particularly impacting marginalised communities.”
The rights organisation referenced international evidence showing the disproportionate impact of facial recognition on Black and Brown people and noted that similar systems have already been subject to legal challenges elsewhere in the UK.
In 2020, the Court of Appeal ruled that South Wales Police’s use of the technology breached privacy, data protection and equality laws. The Metropolitan Police is also facing legal action following the wrongful identification of anti-knife crime activist Shaun Thompson.
Amnesty further criticised recent claims that police forces have mitigated bias in facial recognition algorithms, calling such assertions “scientifically weak” and warning the SPA to treat them “with caution.”
In its letter, Amnesty urged the SPA to publish a detailed public update outlining Police Scotland’s plans for LFR, including any formal evaluations or human rights impact assessments. It also called for an independent review of the force’s existing use of retrospective facial searches — an area where the Scottish Biometrics Commissioner has already found serious monitoring failures.
“Instead of pursuing plans to introduce live facial recognition,” Amnesty said, “Police Scotland, the SPA and the Scottish Government should be working to ensure that technologies of mass surveillance are never deployed in Scotland.”
Amnesty’s intervention highlights growing tension between law enforcement and civil liberties groups over the role of emerging technologies in policing. Critics argue that LFR risks normalising constant surveillance and eroding public trust, while supporters within law enforcement claim it could enhance efficiency and public safety.
Amnesty concluded its letter with a stark warning: “The implications of the decision to move forward with LFR should not be underestimated. Its adoption would represent a historic shift in the relationship between Police Scotland and the public.”
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