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)
November 6, 2025
Is It Time to Prepare Your Self-Assessment Tax Return?

HM Revenue and Customs (HMRC) has been reminding taxpayers that there are now fewer than 100 days left to file their tax return and pay any tax due for the 2024-25 tax year.

Read article
November 5, 2025
Directors’ Report Requirement to Be Removed

As part of its move to reduce ‘red tape’ and aid business growth, the government has announced plans to remove the requirement for companies to include a directors’ report as part of their annual accounts.

Read article