13 April 2023
The Irish Council for Civil Liberties, along with Digital Rights Ireland and academics from the UCD Centre for Digital Policy, the University of Galway, Maynooth University and University College Cork, has written a letter to Data Protection Commissioner Helen Dixon further to a 23 March discussion with the office of the Data Protection Commissioner (DPC) about the Department of Justice’s purported and ongoing plans to enable An Garda Síochána’s use of Facial Recognition Technology (FRT).
Given the Government’s statutory obligation to consult with the DPC prior to the introduction of FRT into Irish policing, the letter outlines factors that the DPC should consider in assessing policing use of FRT in Ireland, informed by recent and guiding research from the Centre for Technology and Democracy, at the University of Cambridge. These factors include:
- Establishing clear, objective criteria
- The necessity of FRT in a democratic society
- Data protection standards
- Consultation (with the public, civil society and independent experts)
- Demographic impacts, including marginalised groups
- Expression and assembly impacts
- Independent evaluation and safeguards
- Technical training for officers
- Vetting the technology
- Oversight and redress
- Handling of biometric data