THIS CONSULTATION IS NOW CLOSED
The field of biometrics is changing rapidly. No longer limited to DNA and fingerprints, technologies like facial, iris and gait recognition are making yesterday’s rules obsolete. Scotland needs an independent body to keep pace.
The Scottish Government has proposed to create a Biometrics Commissioner and it's up to us to make sure they get it right. You have until 1 October to submit recommendations for creating a modern institution equipped with the tools and authority for proper oversight. Use the points below to construct your own unique message.
• Scotland needs a biometrics commissioner. Unlike England, Wales, and Northern Ireland, Scotland is missing an independent body to oversee everchanging biometric techniques, while also protecting the right to privacy.
• Assess the wider impact of biometrics. The commissioner, while beginning at oversight of Police and justice use of biometrics, must extend to every aspect of public life touched by biometrics including education, health sector, workplaces, schools and public offices. A report looking into these other areas should be one of the first pieces of work for the Commissioner to undertake.
• Cover all biometrics. Scotland needs a general definition of biometrics covered by a new code of practice to address emerging technologies like facial and iris recognition. Regulating specific biometric attributes quickly falls short when new technologies are introduced.
• Establish an automatic presumption of deletion. Ordinary citizens must not be treated like criminals. There should be a presumption of automatic deletion of records held by Police when statutory retention periods are met.
• Establish in primary legislation. The biometrics commissioner’s powers, the definition of biometrics, and the presumption of automatic deletion should all be codified in primary legislation. This will convey legitimacy and provide the opportunity for proper debate and scrutiny.