United KingdomEducation2021 – ongoingNorth Ayrshire Council
Facial recognition for school meal payments
North Ayrshire paused facial recognition for school meals after privacy inquiries
Problem
The council introduced facial recognition to identify pupils at lunch tills and debit their catering accounts. It said the system offered faster, more hygienic payments than cards or fingerprint scanners.
Approach
The regulator recorded deployment in nine schools on 6 September 2021, affecting 2,569 pupils. Catering staff took a photograph at the till, and software matched it against enrolled facial templates. The council notified the ICO on 22 October 2021 that it had paused the system; the ICO subsequently concluded that the deployment was likely to have infringed data protection law, including requirements concerning transparency, retention and impact assessment. The council said participation required consent and that pupils could use a PIN instead.
Results
Takeaway
The council's consent arrangements and alternative payment method did not resolve the regulator's concerns about the processing of children's biometric data.
Categories
- Size
- Large enterprise
- Industry
- Education
- Business function
- Production and quality
- Innovation type
- Process innovation
- AI technology
- Computer vision
- Adoption
- Vendor solution
- Evidence
- Regulator, audit or court
Sources
Source summaries
The ICO documented the deployment, payment workflow and October 2021 pause. It identified likely infringements of data protection law and recommended changes to the council's safeguards.
The updated report described the suspension following ICO inquiries. It reported the council's explanation about payment speed, hygiene, consent and a PIN alternative; its rollout chronology differed from the ICO's subsequent account.
Full details are in the original sources.
