Privacy International's response to the College of Policing consultation on the 'ethical use of data and technologies guidance'

Privacy International (PI) provided a written response to the College of Policing consultation on the 'ethical use of data and technologies guidance' through which they sought feedback on two new authorised professional practices (APP) on data ethics and data-driven technologies.  

Key advocacy points

Within our response we highlighted:

  • The police should already be assessing the deployment of data driven technologies in accordance with the laws and regulation outlined in the APP, yet based on their current deployments this doesn’t appear to be the case.
  • Second, whether the APP will help officers come to a legally compliant decision around deployment is not guaranteed
  • Third, there is a bigger issue around the need for specific laws pertaining to these technologies to impose restrictions and safeguards for their use. 
Advocacy
CCTV camera on London underground

In August 2024 the UK College of Policing (CoP) announced they were consulting on new guidance for data ethics and data driven technologies in policing. As part of the consultation the College asked for feedback on two new authorised professional practices (APP) on data ethics and data-driven technologies. PI provided a response in writing to the CoP on their APP on data ethics and data-driven technologies only.

In our response we highlighted that we are aware that UK police forces are using a range of data-driven technologies are already deploying certain technologies including live facial recognition technology ("FRT"), drones, mobile phone extraction, social media monitoring and may be using IMSI catcher. Whislt we recognise that the CoP are developing this guide to ensure police procure, deploy and implement these data driven technologies in line with existing laws and standards, our view is that current regulatory instruments do not provide sufficient safeguards, oversight and accountability for the deployment of certain data-driven technologies. Considering this, our submission simply notes two high-level concerns: first, we provide detail on our concerns relating to the legislative void and second, the application of the APP to existing deployments.