By Professor Fraser Sampson, former UK Biometrics & Surveillance Camera Commissioner
In the same week the UK Prime Minister said shoplifting has ‘wreaked havoc’ on neighbourhoods for years, the first UK supermarket announced a trial of facial recognition technology (FRT). With the government’s focus on prevention and shoplifting stories continuing to make the front pages, it was probably inevitable. But this is uncharted territory for the big high street retailers who will need to tick off a few essentials before heading to the checkout.
First, they need to understand the territory. This is not just any data processing, this is biometric processing. Major retailers have deep and wide experience handling customer data at macro level, but biometrics are elementally different. Using a biometric recognition system in the UK means they are processing ‘special category data’ and biometric data differs even from other types of special categories. This brings a number of significant risks, obligations and restrictions, some technological, some legal, some societal. The opportunities for missteps are many and the consequences profound. An early decision for the supermarket would be whether they want to be the controller, joint controller or processor; an early mistake would be to think it doesn’t matter.
Second, the supermarkets will have used transactional Artificial Narrow Intelligence (ANI) systems before but remote biometrics systems are not like other ANI solutions such as software to transcribe their meetings or track customer spending. Facial recognition in retail is literally customer-facing. As such, it is part of the in-store experience and, unlike some back-office AI solutions, the interface will be a mission critical quality system like safety, reliability and customer service.
Third, supermarkets also have extensive experience of in-store security, but facial recognition is not CCTV. While there are some legal and regulatory overlaps, it is unlikely that either their pre-AI era equipment or operating protocols will be up to the job of reliable, responsible and compliant biometric processing. Another mistake would be to assume that this is all just cameras.
Fourth, facial recognition technology doesn’t come as a plug-and-play purchase (if it does, you’d better check your seller’s returns policy). You can’t just pick it off the shelf, drop it in your trolley and head for the self-service pay point. Selecting a biometric technology partner is not procurement, it’s recruitment. Installing a remote AI-powered biometric system involves both parties entering into an enduring relationship built on mutual trust and confidence. Guidance from the UK data regulator underlines how companies must only use providers who can give sufficient guarantees of the measures they will use for data protection by design; it also says that their choice of biometric recognition system can help to demonstrate compliance with the protection by design and default principle. A wise company will therefore treat this like a hiring issue, requiring candidates to meet a rigorous job specification, minimum qualification levels, relevant experience and due diligence, insisting that both partner and FRT system meet the same consistent quality standards demanded of all its people, products and services.
Going first is easy, going to last is harder. Current activity seems to be about ‘testing’. Developing algorithms in a sandbox environment gives the designer control over variables and is very different from testing kit and concept on the fly. ‘Live trials’ mean that both must prove themselves concurrently within the same short time span before an unfiltered audience. AI-driven biometrics are in permanent beta state and early adopters of FRT have learned that confidence is highly perishable: you must keep it refreshed by continual review and revision after the technical trials. If supermarkets are in any doubt about how demanding and dispiriting all this can be, they should call the police.
AI-enabled innovation is revolutionising many sectors. Some have already embraced and invested in the benefits, such as healthcare providers using AI-powered tools for diagnostics and treatment planning, educational organisations using learning platforms and personalised tutoring systems and general SMEs relying on new AI- tools for transactional automation, data analytics and customer service support. All of these are great examples of balancing innovation, efficiency and ROI; none of them are as complex and nuanced as AI-driven biometric comparison.
Some retailers have already invested successfully in facial recognition technology and the supermarkets would do well to learn from them. Their fellow retailers will tell them how remote biometrics must balance the technological (what can be done) with the legal (what must/must not be done) and the societal (what people expect to be done). In other words, the possible, the permissible and the acceptable must all line up. They will tell them that the Information Commissioner expects full and demonstrable compliance with what he describes as the ‘deliberately stringent’ conditions governing biometric processing.
Retailers already using FRT know that choosing a remote biometric system is a brand-compatibility decision. Biometric recognition systems are still in their technological, societal and even legal infancy, attracting some apprehension and strident opposition. Pioneering supermarkets will need to understand this too.
Retail is a bit like the tech world, storied with trailblazers who broke the mold and transformed the game. Their quotes are among the most searched for online. One such quote comes from Gap’s Mickey Drexler who warned that in retail, consistency is everything, that ‘people want to come in and see what you are famous for’. Venturing into facial recognition, UK supermarkets will need to be, not just consistent but also conscientious or they may find biometric fame for the wrong reasons.
About the author
Fraser Sampson, former UK Biometrics & Surveillance Camera Commissioner, is Professor of Governance and National Security at CENTRIC (Centre for Excellence in Terrorism, Resilience, Intelligence & Organised Crime Research) and a non-executive director at Facewatch.
Article Topics
biometrics | criminal ID | facial recognition | Fraser Sampson | retail biometrics
https://www.biometricupdate.com/202504/caution-urged-as-uk-supermarkets-check-out-facial-recognition