Langham Walsh

Guidance for small businesses on using facial recognition technology

Talk to an expert

Facial recognition technology (FRT) identifies or otherwise recognises a person from a digital facial image. Businesses can use FRT in a variety of contexts - for example, in allowing access to devices, taking payments, or allowing entry to secure areas.


Depending on the use, FRT involves processing personal data, biometric data and special category personal data. Such technologies can intrude on people's privacy, so businesses need to think carefully when deciding if they should implement them.


If you are a small business looking to begin using facial recognition technology, read the ICO's latest FAQ about using FRT for payment, entry, or other security systems.


The information highlights key issues to be aware of, such as:

  • what you need to consider before using this technology;
  • when you must complete a data protection impact assessment;
  • how to identify and satisfy a special category condition; and
  • what to include in your privacy notice if you use FRT.
    See: [Additional considerations for technologies other than CCTV | ICO](https://ico.org.uk/for-organisations/guide-to-data-protection/key-dp-themes/guidance-on-video-surveillance-including-cctv/additional-considerations-for-technologies-other-than-cctv/#frt)
March 26, 2026
Is Faster Broadband Coming to your Premises?

A new GOV.UK service allows businesses and individuals to find out whether their address is due a broadband upgrade. By entering your postcode, you can see whether your premises or home is covered by rollout plans.

Read article
March 25, 2026
Is Your Business Ready for 2026/27?

With 6 April 2026, ushering in the start of the new tax year, there are some changes on the way that may affect how you run and plan for your business. To help you stay ahead, we have highlighted three key updates worth having on your radar.

Read article