Police forces and the National Crime Agency have been urged to strengthen safeguards around retrospective facial recognition after an inspection found inconsistent oversight and gaps in investigators’ understanding of the technology.
The inspection, published on 12 November, makes 16 recommendations covering supervision, training, national guidance and the management of searches. It found that the technology can be a valuable investigative tool, but that public confidence depends on its use being lawful, proportionate and open to scrutiny.
Inspectors examined seven forces, including the Metropolitan Police, as well as the National Crime Agency. Their fieldwork took place between March and April 2026. The findings describe the organisations and arrangements examined; they are not a finding that every force has the same shortcomings.
What a search can and cannot establish
Retrospective facial recognition involves taking an existing image, such as a frame from CCTV or footage from a doorbell camera, and comparing it with photographs held in a database. It differs from live facial recognition, which compares people passing a camera with a watchlist during a deployment. The inspection focused on the retrospective technology.
A search can produce a list of possible matches for a trained operator to review. It does not, on its own, establish a person’s identity or prove involvement in an offence. Investigators need to make further enquiries and corroborate a possible match before taking enforcement action.
Inspectors found that experienced investigators generally understood that distinction, but some less experienced staff did not. In one force’s focus group, more than half the participants did not know that the results were for intelligence purposes only. The inspection also identified a small number of cases where officers placed too much reliance on potential matches.
The stakes are significant. An incorrect identification can lead to unnecessary police action against someone who has done nothing wrong. Human review is intended to be a safeguard, but it depends on officers understanding what the software can and cannot tell them.
Gaps in oversight and records
Four of the inspected forces had not developed local guidance and relied on limited national publications. Others had more detailed policies or regular meetings where senior staff considered performance and governance. Inspectors found no clear structure for overseeing the technology in some forces.
Record keeping was another concern. Forces often held limited information on how a search result related to later investigative decisions or case outcomes. That made it difficult to assess both the benefits of the technology and any adverse effects.
Police forces in England and Wales carried out 291,341 retrospective searches on the Police National Database in the year to 31 March 2026. The number varied substantially between forces. The figure counts searches, not arrests or successful identifications, and does not establish how many investigations the technology resolved.
Inspectors also found that some custody images which should have been deleted under existing retention rules remained available for facial recognition searches. Keeping images that should no longer be held raises questions about whose photographs can be returned in a search and how reliably retention rules are applied.
Separate testing in 2024 found that, at some settings, the database algorithm was more likely to include people with certain protected characteristics incorrectly in its results. Police have taken steps to address algorithmic bias. Because the available records did not link searches sufficiently to arrests and outcomes, inspectors could not establish with certainty whether the identified bias had contributed to any wrongful arrests.
Changes recommended for 2027
The recommendations seek changes at several stages of a search, from assessing data protection risks to recording how an investigator acts on a possible match. They are proposals for the bodies concerned, not measures that have already been implemented.
By 30 June 2027, inspectors want the Home Office to introduce a requirement for a statutory code of practice covering law enforcement use of retrospective facial recognition. The proposed code would address lawful purposes, oversight, training, testing and the handling of results, including human review and corroboration.
Chief constables and the National Crime Agency’s director general are asked to ensure that data protection impact assessments are carried out and recorded by the same date. Forces are also urged to have arrangements for working with local communities and being open about their use of the technology.
By the end of 2027, inspectors want mandatory training for officers and relevant staff involved in using retrospective recognition, alongside continuing professional development. They also recommend that forces and the agency consider using centralised or established teams for searches, and that a national oversight framework cover police facial recognition, including retrospective use.
The inspection follows an earlier government plan for legislation and independent oversight of police facial recognition. The newer report adds an examination of how retrospective searches are being used now. Its proposed deadlines do not mean that a new code, training system or oversight framework is already in force.
