Biometric facial recognition use in schools

The request was successful.

Dear West Lothian Council,

Ref: Facial recognition use in schools re your email to me dated 28 September 2021 which you stated that:
"WLC are currently working towards the use of facial recognition technology for cashless catering in 11 high schools."
"Implementation date has still to be confirmed.
The company who will be supplying the technology is CRB Cunninghams."

Under the Freedom of Information (Scotland) Act 2002 pease supply the following data:

1) Please advise where the students, photographic/biometric, facial data source is that works with the facial recognition system. I.e. the Schools Information Management System (SIMS) or a separate data base or other. I.e. Do students have a separate photograph taken for SIMS and a separate photograph for the facial recognition system?


2) Please provide a copy of the biometric consent form sent to parents and students for their consent to have their data processed by the facial recognition system and detail the ages of consent of pupils that will give consent without their parents/carers consent and how that age determination was reached.

3) Are the facial scanners interactive, i.e. the student has to present their face to a scanner, or do the scanners require no specific interaction, i.e. the student does not have to consciously present their face to a scanner.


4) Please advise what alternative to the facial recognition system is offered as an alternative to students that do not wish to use the biometric facial recognition system.



6) Please provide any Data Protection Privacy Impact Assessment you have done for the facial recognition system.

7) Please provide all communications had with the company supplying the facial recognition system and internal communications within the council on the use of facial recognition in schools, including legal advise undertaken internally or externally, including the Information Commissioner's Office.
I understand some parts may need to be redacted under Part 2 of the Act, regarding commercial interests, in which case I wish to received all communications redacted or otherwise.

8) Please advise planned implementation date of the facial recognition.

Some parts of this request may be easier to answer than others and in such case please could you release available data as soon as possible rather than delay the entire request. If you are not fully certain of what it is I am asking then I look forward to contact from you as soon as possible to clarify what it is I am requesting in order to meet your obligations under the law.

If the costs of processing this request exceed the limit in the Act, please advise on what information you are able to supply within the cost limit.

Yours faithfully,

Pippa King

Customer Service, West Lothian Council

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Our Reference: 101007193232

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West Lothian Council

Reference no. 101007193232
MIME-Version: 1.0
Content-Type: text/plain; charset=UTF-8
Content-Transfer-Encoding: 7bit

07/01/2022

Dear Ms King

Freedom Of Information

Reference no. 101007193232

I refer to your request for information dated 3 January.

Your questions and our responses are as follows:

1) Please advise where the students, photographic/biometric, facial data source is that works with the facial recognition system. I.e. the Schools Information Management System (SIMS) or a separate data base or other. I.e. Do students have a separate photograph taken for SIMS and a separate photograph for the facial recognition system?

We do not use any facial recognition systems. WLC had begun to consider cashless catering in secondary schools using facial recognition, but this has not been progressed.

2) Please provide a copy of the biometric consent form sent to parents and students for their consent to have their data processed by the facial recognition system and detail the ages of consent of pupils that will give consent without their parents/carers consent and how that age determination was reached.

N/A

3) Are the facial scanners interactive, i.e. the student has to present their face to a scanner, or do the scanners require no specific interaction, i.e. the student does not have to consciously present their face to a scanner.

N/A

4) Please advise what alternative to the facial recognition system is offered as an alternative to students that do not wish to use the biometric facial recognition system.

N/A

6) Please provide any Data Protection Privacy Impact Assessment you have done for the facial recognition system.

N/A

7) Please provide all communications had with the company supplying the facial recognition system and internal communications within the council on the use of facial recognition in schools, including legal advise undertaken internally or externally, including the Information Commissioner's Office.

I understand some parts may need to be redacted under Part 2 of the Act, regarding commercial interests, in which case I wish to received all communications redacted or otherwise.

N/A

8) Please advise planned implementation date of the facial recognition.

N/A

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Yours Sincerely

Hannah Haywood

Customer Services Manager
Education Services

West Lothian Council

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