Dean Armstrong KC has assisted Facewatch, the UK facial recognition technology company, with expert advice on personal data policy. Mr Armstrong’s advice has led to a successful outcome when key aspects of its personal data processing were recently assessed by the United Kingdom Information Commissioner’s Office (ICO).
Commissioned by ELIAS Partnership, a data rights and governance advisory firm, Dean Armstrong KC provided critical advice in respect of this matter.
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The ICO investigation, which took four years, involved scrutiny of Facewatch technology which is used by major retailers such as The Southern Co-op and Frasers Group. Anyone responsible for committing a crime is added to the system by stores. The logging of this information requires the store to sign a legal declaration before all matches are double checked by specialist analysts and sent as alerts. To protect the personal data of genuine store customers, the technology instantly discards biometric data from shoppers unless it is matched with ‘subjects of interest’ in its database. The investigation has resulted in Facewatch receiving a ‘most commendable’ rating by the UK Biometrics Commissioner, Professor Fraser Sampson.
Facewatch Chairman Nick Fisher said: “I would like to thank Dean Armstrong KC for his exemplary representation in this matter. The decision by the ICO is a vote of confidence and underlines our commitment to best practice, both to prevent crime and protect staff and customers. The public and our subscribers can continue to have confidence in our systems and privacy safeguards.”
Dean Armstrong KC comments, “Facewatch has been able to prove that by operating within the scope of personal data legislation, facial recognition technology can play a role in reducing crime. I am delighted with this outcome for Facewatch.”
Dean is a specialist in the law relating to digital assets and the blockchain, encompassing cryptocurrency, non-fungible tokens, and smart contracts. With expertise that spans cyber (digital) law in general, Dean is also able to assist clients with legal matters relating to cyber insurance and the intersection of cyber and data law. Dean has written textbooks on cryptocurrency and the blockchain as well as cyber security, cyber litigation and cyber insurance. He is also highly experienced in international insolvency work, especially involving crypto assets. He is also experienced in cases involving allegations of international and UK fraud.
Ranked by Chambers and Partners in Band 1 for crypto assets, Dean is the only silk to lead on the Commercial Bar’s response to the Law Commission on its draft on digital assets. Dean has also advised on the draft of the Virtual Asset Service Provider Rules.
Dean Armstrong KC
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