The Minister for Justice plans to expand Garda surveillance powers with policing facial recognition technologies (FRT). While some believe that using FRT may help make us safer, the undersigned experts from seven universities and 13 NGOs in Ireland know the risks are too significant.

Policing FRT is used as a form of mass surveillance that will enable the identification and tracking of individuals without warranted suspicion. It has the ability to scan large amounts of publicly captured visual data so it can draw powerful inferences about people, the vast majority of whom would be of no interest whatsoever to the gardaí. While public safety and national security can sometimes supersede privacy rights, the intrusions of policing FRT surveillance are wholly unnecessary and disproportionate. There is a danger that the use of FRT will have significant chilling effects, altering how people use public and online spaces.

Even though this technology is available for policing, it does not mean we should use or trust it. It is established by independent researchers to be biased and discriminatory, particularly for anyone who is not a white man. Scientists agree that the technology is simply not advanced enough and does not live up to the claims of its developers. However, even if accuracy were to improve, because the technology can be deployed indiscriminately, it risks increasing the problem of over-policing in areas with marginalised  groups, leading to disproportionate incrimination, racial and minority ethnic profiling, and derailing of people’s lives.

Meanwhile, data protection risks abound according to leading European authorities. The gardaí already have unresolved issues surrounding the use of CCTV, ANPR, drones and body worn cameras. It is important for Irish authorities to resolve these concerns before adopting new technologies like FRT which also rely on the gathering and analysis of large amounts of data.

While the government is attempting to create a legal basis for FRT use by amending the An Garda Síochána (Digital Recording) Bill, this seems premature given Ireland will be subject to the provisions of the forthcoming European AI regulatory framework. We question why the government is rushing to legalise this very risky technology at the committee stage, thereby bypassing the usual democratic opportunities for consultation and robust debate?

The risks presented are significant enough in a policing context that they cannot currently be safeguarded by legislation. There are currently no circumstances in which policing FRT can be safely rolled out in Ireland. We have seen similar concern from academics, civil societies, politicians and stakeholders around the world, including calls for bans from the European Parliament. The Irish Council for Civil Liberties has launched a campaign.

It is important for the minister to recognise the dangers of this intrusive technology and to look at the emerging research by independent experts. We ask that minister McEntee choose the safest approach for Ireland and install a full moratorium on policing FRT.

Yours sincerely,

Elizabeth Farries
Assistant Professor and Co-Director, UCD Centre for Digital Policy

Ciara Bracken-Roche
Assistant Professor, School of Law and Criminology, Maynooth University

Aphra Kerr
Professor, Department of Sociology, Maynooth University

Barry O’Sullivan,
Professor FAAAI, FEurAI, FIAE, FICS, MRIA, Insight SFI Research Centre for Data Analytics, UCC

Rob Kitchin
Professor, Maynooth University Social Sciences Institute, MRIA

Liam Herrick
Executive Director, Irish Council for Civil Liberties

Olga Cronin
Policy Officer, Irish Council for Civil Liberties

Abeba Birhane
Assistant Professor, cognitive science researcher, Complex Software Lab, UCD

Adeline Berry
Chair, Intersex Ireland

Andrea Renda
Professor, Centre for European Policy Studies, EUI, UCD Centre for Digital Policy

Antóin Ó Lachtnáin
Director, Digital Rights Ireland

Brian Collins
Interim Advocacy Service Manager, Nasc, the Migrant and Refugee Rights Centre

Brian Killoran
CEO of Immigrant Council of Ireland

Bulelani Mfaco
Spokesperson for the Movement of Asylum Seekers in Ireland

Colm O’Gorman
Executive Director of Amnesty International Ireland

Dave Lewis,
Associate Professor, Head of the AI Discipline, School of Computer Science and Statistics, TCD

Doireann Ansbro,
Head of Legal and Policy, ICCL

Edel McGinley,
Director, Migrant Rights Centre Ireland

Eoin O’Dell
Associate Professor, School of Law, TCD

Eugenia Siapera
Professor, Head of School, Co-Director, UCD Centre for Digital Policy

Gavan Titley
Associate Professor of Media Studies at Maynooth University

Giuseppe Mazziotti
Fellow and Professor, Trinity College Dublin, School of Law

Jason Kalathas
PhD Student/Researcher at UCD School of Information & Communication Studies

Dr Johnny Ryan
Senior Fellow, ICCL

Kalpana Shankar
Professor, School of Information and Communications Studies, UCD

Dr Kris Shrishak,
Technology Fellow, ICCL

Kylie Jarrett
Associate Professor, Department of Media Studies, Maynooth University

Lai Ma
Assistant Professor, Director of MLIS and GradDipLIS Programmes, ICS, UCD

Laura Nolan
Tech Inquiry

Layla Wade
Campaigner, Uplift

Liz Carolan
Member, UCD Centre for Digital Policy

Dr Marco Bastos
Ad Astra Fellow, Executive, UCD Centre for Digital Policy

Marguerite Barry
Associate Professor, School of Information and Communications Studies, UCD

Martin Collins
Co-Director, Pavee Point Traveller and Roma Centre

Matt Bowden
Senior Lecture at Technical University of Dublin

Páriac Kerrigan
Assistant Professor School of Information and Communications Studies, UCD

Michael Madden
Professor, School of Computer Science, NUI Galway

Adv. Nery Ramati
Human Rights Lawyer, PhD Candidate, School of Law and Government, DCU

Dr Niamh Kirk
Lecturer, University of Limerick, Visiting Fellow, UCD Centre for Digital Policy

Paloma Viejo Otero
Post Doctoral Research, Ireland

Philipp Roseman
Professor and Chair of Philosophy at Maynooth University

Dr Róisín Á Costello BL
Ollamh Cúnta/Assistant Professor, School of Law and Government, DCU

Rozenn Dahyot
Professor of Computer Science at Maynooth University (Ireland)

Shane O’Curry
Director, Irish Network Against Racism

Simon McGarr
Solicitor, Digital Rights Ireland

Dr Stefanie Havelka
Teaching Fellow, School of Information and Communication Studies, UCD

Dr Stephen Farrell
Research Fellow, School of Computer Science and Statistics, TCD

Susan Leavy
Assistant Professor, School of Information and Communications Studies, ADAPT SFI

temi lasade-anderson
Advisory Board, UCD Centre for Digital Policy, PhD Student, King’s College London

Tijana Milosevic
Elite-S research fellow DCU Anti-Bullying Centre and ADAPT SFI

Tina Kolos Orbán
CEO, Transgender Equality Network Ireland

TJ McIntyre
Associate Professor, Sutherland School of Law, Chair, Digital Rights Ireland

Dr Vicky Conway
Associate Professor, School of Law and Government, Dublin City University