Use of Facial Recognition Technology following ICO Case Report
Dear Kingsmeadow Community Comprehensive School, Gateshead,
1) Are Kingsmeadow Community Comprehensive School still using facial recognition technology?
2) If the answer is Yes to Q1 please answer the below questions a-d, these are being asked in relation to the ICO’s recent publication of a test case on the use of facial recognition technology in schools: https://ico.org.uk/for-organisations/gui...
a) Please advise or provide documents or communications (email, text, video conference etc) where Kingsmeadow Community Comprehensive School “evidence that the use of the FRT is a necessary and proportionate way to manage payments for a school lunch service. This includes considering whether less intrusive alternatives are available.”
b) The education authority must “make it clear what they will do with the [students special category biometric] data, whether there is any sharing of personal information with a supplier, and the retention policy for the data." and whether any facial data is available to CRB Cunninghams. Please also supply any communication to parents/carers and students in this respect.
c) Your FOIR reply on 4th July 2022 https://www.whatdotheyknow.com/request/a... stated that neither Kingsmeadow Community Comprehensive School or CRB Cunninghams log any incidences of false positives or false negatives with regards to the facial recognition technology. The above recent ICO Case Report states that the education authority “must also explain to pupils or those parents/carers the risks related to the processing of special category biometric data; technologies such as FRT rely on the use of AI and algorithms and present two key risks - bias and discrimination.”
Please supply any communication to parents/carers, students and CRB Cunninghams since July 2022 to explain or discuss the risks associated with the facial recognition biometric processing and what methods Kingsmeadow Community Comprehensive School have in place for monitoring the facial recognition technology potential for bias and discrimination.
d) With reference to the above ICO link, “The education authority will need to comply with its transparency obligations by creating a children friendly privacy notice that contains all the information required under UK GDPR.” Please supply any communication to parents/carers and students in this respect.
3) If the answer is No to Q1 please advise the reason why and what system/s have replaced the facial recognition technology.
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.
I am grateful for your time on this as I appreciate schools are busy.
Yours faithfully,
Pippa King
Dear Pippa
Thank you for your email and questions, which has been received today due
to school being closed for half term last week.
In respect of question 1, I can confirm that Kingsmeadow are still using
facial recognition software. This renders question 3 not applicable.
With regards to question 2 (points a-d), I will look in to this for you
and aim to get back to you by the end of this week with the required
information. I have not long been in post – I believe previous
correspondence had been with my predecessor Maxine Webb.
Many thanks,
Kind regards,
Catherine
Miss Catherine Bulman
School Business Manager
Tel: 0191 4606004 x 258
[1]https://ci3.googleusercontent.com/mail-s...
This communication is from Kingsmeadow School. The information contained
in this communication and/or attachment is confidential. It is for the
exclusive use of the intended recipient. If printed, paper copies should
be locked away so not accessible to others. If you are not the intended
recipient, please do not distribute, copy or otherwise use this
communication or the information in it. If you have received this
communication in error, please notify us by return e-mail and then delete
the e-mail (including any attachments) and any copies of it.
From: Domenic Volpe <[Kingsmeadow Community Comprehensive School, Gateshead request email]>
Sent: 27 February 2023 08:07
To: Catherine Bulman <[email address]>
Subject: Fwd: Freedom of Information request - Use of Facial Recognition
Technology following ICO Case Report
Domenic Volpe
Headteacher
Kingsmeadow Community School
Market Lane
Dunston
Gateshead
NE11 9NX
Tel: 0191 4606004
Web: [2]www.kingsmeadow.org.uk
Dear Pippa,
Thank you for your email of 21^st February 2023 where you requested
information about Facial Recognition Software.
We have now completed searching for the information you requested.
1) Yes
2) -
2a) Please find attached a copy of our parent consent form and also our
DPIA.
2b) Please find attached a copy of our parent consent form.
2c) Not applicable
2d) Not applicable
3) Not applicable
If you are dissatisfied with the handling of your request, you have the
right to ask for an internal review. Internal review requests should be
submitted within two months of the date of receipt of the response to your
original letter and should be addressed to: Mr D Volpe; Head Teacher,
Kingsmeadow School. Please provide full details of the reasons why you
believe your request was not handled properly.
If you are not content with the outcome of the internal review, you have
the right to apply directly to the Information Commissioner for a
decision. The Information Commissioner can be contacted at: Information
Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9
5AF.
Thank you and kind regards,
Catherine
Miss Catherine Bulman
School Business Manager
Tel: 0191 4606004 x 258
[1]https://ci3.googleusercontent.com/mail-s...
This communication is from Kingsmeadow School. The information contained
in this communication and/or attachment is confidential. It is for the
exclusive use of the intended recipient. If printed, paper copies should
be locked away so not accessible to others. If you are not the intended
recipient, please do not distribute, copy or otherwise use this
communication or the information in it. If you have received this
communication in error, please notify us by return e-mail and then delete
the e-mail (including any attachments) and any copies of it.
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