For Heads-of · Practitioner

Untargeted facial recognition scraping

Facial images are scraped from the internet or CCTV footage without targeting, to build or expand a facial recognition database.

  • critical
  • prohibited-practice
  • biometric
  • facial-recognition
  • eu-ai-act

How it happens

A system or process indiscriminately collects facial images from public internet sources or camera footage, without any pre-existing target or lawful basis specific to those individuals, purely to grow a facial recognition dataset.

Why it matters

The absence of targeting is the distinguishing feature: this isn't a case-by-case investigative tool, it's mass, non-consensual biometric data collection at a scale no individual could reasonably anticipate or object to.

Mitigating controls

The controls that address this risk, ranked by effectiveness.

No controls mapped to this risk yet.

Framework and clause references

FrameworkClauseTitle
EU AI ActArticle 5(e)Untargeted facial recognition scraping
UK General Data Protection RegulationArticle 5Principles relating to processing of personal data

Related resources

The external sources behind this risk, from the Resources library.