Facial Recognition Technology
Our key call: Any future legislative framework for facial recognition technology must demonstrate compliance with children’s rights in Wales
Facial Recognition Technology (FRT), including live facial recognition used by police in public spaces, is being rolled out across the UK and has been used extensively in South Wales. While policing is not devolved, the use of this technology has clear and serious implications for children’s rights. Evidence shows that FRT is often inaccurate, disproportionately misidentifies children and people from racialised communities, and risks normalising intrusive surveillance in everyday public life and spaces children use in their daily lives.
In Wales, these risks are especially significant because Welsh law requires children’s rights to be properly considered in all policy and legislative development. Wales has a distinctive legal framework that sets it apart from the rest of the UK. Under the Rights of Children and Young Persons (Wales) Measure 2011, Welsh Government Ministers must give due regard to the United Nations Convention on the Rights of the Child (UNCRC) in the exercise of any of their functions. However, the UK Government’s current consultation on facial recognition technology does not adequately consider children’s rights, nor does it address how new legislation would align with Wales’s existing commitments. At present, there is no clear evidence that proposed approaches either consider, or comply with the UNCRC and Wales’s child-rights legislative duties.
BRIEFING
The Use of Facial Recognition Technology: Implications for Childrens Rights
February 2026
CONSULTATION RESPONSE
Response to the UK Government Consultation on
Facial Recognition Technology
Dr Rhian Croke (Children’s Legal Centre Wales) & Dr Michelle
Coleman (Swansea University School of Law).
February 2026

