9 October 2026

9 October 2026: Facial Recognition Comes to Your Council — But Who Was Asked?

Seen. Not Processed. | Investigation Update

For the past seven weeks, Seen. Not Processed. has been investigating police use of facial recognition technology across the UK.

Our Freedom of Information requests to 46 police bodies have concentrated on one fundamental question:

What evidence demonstrates that biometric data is being handled, retained and deleted in accordance with the safeguards the police say are in place?

That investigation continues.

But recent reporting has revealed something that takes us into another area of public surveillance entirely.

Local councils are now operating facial recognition technology within their CCTV networks.

And in at least one case, the police are reportedly supplying the names and images of people they want those systems to identify.

That raises questions extending well beyond the technology itself.

From recording people to identifying them

An investigation published by Liberty Investigates on 29 August 2026, followed by BBC reporting, identified two councils using facial recognition technology.

Preston City Council confirmed that 130 CCTV cameras have facial recognition capability. According to the council, just one currently operates a facial recognition watchlist, inside its One Stop Shop, where residents access public services. That watchlist reportedly contains a single individual who has been banned from the town hall.

North Tyneside Council presents a considerably different picture.

It has 193 cameras reportedly operating facial recognition watchlists, with individuals added at the request of Northumbria Police.

This is not simply an improvement in CCTV picture quality.

Traditional CCTV records images that can subsequently be examined. Facial recognition can analyse someone's facial features and compare them against a database of identities.

The distinction matters.

Someone walking along a public street may reasonably expect to encounter CCTV. Whether they expect their face to be subjected to automated biometric comparison is another matter entirely.

And who decided this was an acceptable development?

The police were consulted. The public wasn't.

We examined North Tyneside Council's Cabinet papers from 16 February 2026, including its revised CCTV policy and accompanying Equality Impact Assessment.

The Cabinet report expressly acknowledges that many of the council's CCTV systems use facial recognition and artificial intelligence technologies.

It also records that Northumbria Police was consulted during development of the revised CCTV policy.

The public, however, was not consulted on that policy.

The council explained that opportunities for residents to influence its content were constrained by statutory and regulatory requirements.

That is the council's recorded explanation, and it deserves examination.

North Tyneside has conducted wider engagement about community safety. Residents have expressed concerns about antisocial behaviour and crime, and the council has responded with investment in surveillance technology.

There is nothing unreasonable about residents wanting safer streets or councils considering technology that may help provide them.

But there is an important distinction.

Asking residents whether they want safer communities is not the same as asking whether they support biometric identification in public spaces.

We have not yet established whether any separate public consultation specifically addressed the introduction of facial recognition.

That is a question we intend to pursue.

Public consultation and individual consent are also different matters. Data protection law does not necessarily require consent for every public-authority use of biometric recognition. Other lawful grounds may apply, provided the relevant conditions are satisfied.

But a potential lawful basis does not automatically settle the wider questions of necessity, proportionality, transparency and public accountability.

People should be able to understand what technology is being used, why it is necessary, and what safeguards protect them.

When police provide the watchlist, whose safeguards apply?

This is perhaps the most important development in our investigation.

According to Liberty Investigates, Northumbria Police requests the addition of individuals to facial recognition watchlists operating through North Tyneside Council's camera network.

Think about that arrangement.

The police identify people they want the system to locate.

The council operates the surveillance infrastructure.

A technology supplier provides the software that processes the information.

There may be perfectly legitimate reasons for such cooperation. Locating vulnerable missing people, identifying serious offenders and improving public safety are objectives deserving serious consideration.

But responsibility for the resulting biometric processing must be clear.

Police-operated live facial recognition is generally associated with defined deployments, specific watchlists, authorisations, operational assessments and retention safeguards.

What happens when the same identification capability is operated through a permanent council CCTV network?

Does the council apply equivalent safeguards?

Are the police's own watchlist selection and authorisation requirements followed when they request additions?

Does Northumbria Police verify the council's retention, deletion and audit arrangements?

And who is ultimately responsible if something goes wrong?

We are not suggesting that Northumbria Police is deliberately circumventing its own safeguards. There is no evidence currently establishing that.

But we do need to understand whether this partnership arrangement has the effect of operating outside safeguards normally associated with police facial recognition deployments.

There is also a critical question about operating times.

Police facial recognition vans generally operate during defined periods. A council's fixed CCTV network may run continuously.

Are biometric watchlist comparisons taking place continuously across North Tyneside's cameras, or only during separately authorised operations?

The reported existence of watchlists across 193 cameras does not, on its own, establish that matching occurs continuously. We need the operational records to establish that.

If it does operate continuously, that would represent a materially different surveillance model from a time-limited police deployment.

And it deserves corresponding scrutiny.

Significantly, the Information Commissioner's Office identified this very type of partnership arrangement in its February 2026 response to the government's consultation on biometric regulation.

The ICO discussed situations where law enforcement agencies work with local authorities operating facial recognition systems and stressed the importance of clearly defined accountability.

This is not a concern invented by campaigners. It is a governance issue recognised by the UK's data protection regulator.

Sharing responsibility must not mean losing accountability.

What do the council's own safeguards actually say?

North Tyneside's CCTV policy includes commitments concerning privacy assessments, signage, data retention, auditing and oversight.

That is welcome.

However, the documents we examined leave several important questions unresolved.

The Cabinet report acknowledges facial recognition use, yet the accompanying CCTV policy's compliance table marks the principle governing biometric reference-database matching as not applicable at the time it was prepared.

That may reflect the timing of the introduction of the technology or an assessment that was subsequently updated.

We need to establish which.

The council's Equality Impact Assessment also identified no negative impacts on protected groups.

Yet that same assessment scheduled a further review of the effects of AI-powered CCTV on protected and individual characteristics, with a deadline of 30 June 2026.

We have not established whether that review was completed or what it found.

Given the potential consequences of incorrect facial identification, these are not trivial questions.

Nor are they allegations of wrongdoing.

They are questions arising directly from the council's published documents.

What happens to everybody else's face?

This brings us back to the original purpose of Seen. Not Processed.

Every time a facial recognition system compares someone's face against a watchlist, it must process information to conduct that comparison.

What happens when there is no match?

North Tyneside's CCTV policy states that most recorded video footage is overwritten after 30 days, with shorter periods applying to certain systems.

But video footage retention and biometric template retention are not necessarily the same thing.

We want to establish what happens to the temporary biometric information generated during facial recognition.

Is it deleted immediately following an unsuccessful comparison?

What happens to alerts, cached information and watchlist records?

Does the software create evidence that deletion was completed?

Can the council detect a deletion failure?

And what independent or supplier-provided assurance demonstrates that the system works as intended?

A policy stating that information is deleted is not evidence that deletion actually occurred.

We have been asking police forces this question since August.

There is no reason why councils operating comparable technology should not be asked the same thing.

Particularly where a police force is reportedly providing the individuals the system is intended to identify.

How is the public benefit being measured?

There is another aspect that deserves attention.

The councils have argued that their CCTV systems contribute to public safety, crime prevention and responses to antisocial behaviour.

Those are legitimate objectives.

But introducing biometric identification also introduces risks and costs that need to be weighed against the benefits.

How many successful identifications have occurred?

How many alerts were incorrect?

What interventions resulted directly from facial recognition rather than conventional CCTV?

What checks have been undertaken for differing identification accuracy across demographic groups?

What alternatives were considered before facial recognition was introduced?

And has anybody independently assessed whether the claimed benefits justify the processing of biometric information from people who are not suspected of wrongdoing?

We are not asking councils to abandon useful technology simply because it raises difficult questions.

We are asking them to demonstrate that the technology is necessary, proportionate, effective and subject to meaningful oversight.

That should be an entirely reasonable expectation of any publicly funded organisation.

Our investigation is expanding

On 9 October 2026, Seen. Not Processed. submitted a Freedom of Information request to North Tyneside Council.

It asks for recorded evidence of biometric deletion, technical assurance, compliance audits, retention incidents and the responsibilities of the council, Northumbria Police and technology suppliers.

We also intend to examine the police side of that partnership, particularly watchlist authorisation, data sharing, independent oversight and accountability.

Preston City Council's use of facial recognition will form a separate line of enquiry.

We will assess each council against its own stated arrangements and the applicable legal and governance requirements.

If the evidence demonstrates that appropriate safeguards are working, we will publish that.

If it reveals gaps, unanswered questions or weaknesses in assurance, we will report those too.

The purpose is not to manufacture a controversy.

It is to establish what is actually happening.

Public safety should not come at the expense of public accountability

Local councils are responsible for services that affect virtually everybody living in their communities.

Residents have little practical choice about using public streets, accessing council facilities or moving through their own neighbourhoods.

That makes transparency particularly important when councils introduce systems capable of identifying individuals through their biometric characteristics.

And when those systems operate in partnership with the police, the questions become more significant still.

Who authorised the arrangement?

Who assessed whether it was necessary?

Were residents given a meaningful opportunity to understand and challenge the decision?

Whose safeguards apply?

Who verifies that unwanted biometric data is deleted?

And who is accountable when something goes wrong?

These are not unreasonable questions.

They are the questions that should accompany the introduction of powerful surveillance technology into everyday public life.

The ability to identify somebody does not, by itself, establish the justification for doing so.

And residents wanting safer streets should not be interpreted as giving blanket approval for biometric surveillance.

Our investigation began with police forces.

It now extends to local authorities and the arrangements through which public bodies share facial recognition capabilities.

The central principle has not changed.

Public space is not public ownership of your identity.

Trust requires evidence.

SEEN. NOT PROCESSED.

The right to be seen, but not processed.