Open letter


Brodie Clark

Head of the Border Force

2 Marsham Street

London SW1P 4DF


Your ref. TO 12820


4 August 2009




Dear Mr Clark


Thank you for your letter dated 26 June 2009 [1].

The use of biometrics based on facial geometry has a long history of uninterrupted failure [2].

The UK Border Agency (UKBA) are nevertheless testing face recognition again [3], this time with "smart gates" which are meant to check people's faces against their passports. You say:

We ... believe that the gates will deliver an improved service to our customers whilst allowing us to deploy our staff intelligently to areas of greater risk.


Naturally, improvements for travellers and the intelligent deployment of staff are to be applauded. The question is whether face recognition technology can deliver those benefits.

You cite the Face Recognition Vendor Test 2006 (FRVT2006) [4] as one reason to believe that this technology now works:

The test’s findings demonstrated considerable improvement in this field, and confirmed that the technology could be applied successfully in a one-to-one (verification) mode.


This is the only trial of facial recognition technology that you cite. There is no earlier trial that you appeal to, and no later one. Are UKBA right to place so much faith in this one trial?

No. The results of the trial suggest that between 8% and 19% of travellers cannot have their identity verified by facial recognition technology [5]. Are UKBA going to stop between 8% and 19% of passengers from boarding their flights? Surely not. The US show no sign of believing the trial report, they are not deploying facial recognition technology in US-VISIT. Why are the UK deploying it?

Noticeably, you do not cite any evidence from UKBA's own trials of facial recognition technology at Manchester and Stansted airports. The Manchester trial started last August. A year later, no results have been published. Why not?

The inevitable suspicion is that facial recognition technology continues to be as unreliable as it always has been and that it will not improve the lot of travellers and that it will not allow UKBA to concentrate its staff on high risk areas.

You say in your June 2009 letter:

The Home Secretary’s pledge to introduce gates at a total of 10 UK airport terminals by August [2009], includes the two current sites at Manchester and Stansted. It will provide a further opportunity to test the technology on larger numbers of passengers, across a broader range of locations. It also means that the gates will be available to British and EEA citizens throughout the busy summer holiday period.


So the testing of facial recognition technology continues.

But in February 2009, UKBA announced a 10-point delivery plan [6], which consists of several "pledges". One of those pledges is, by August 2009, to have ...

... completed delivery of new facial recognition technology in 10 terminals, giving British passengers a faster, secure route through the border.


No hint there that the technology is just being tested, it might work, it might not. In that respect, the 10-point delivery plan press release is misleading.

The evidence suggests that relying on facial recognition technology is a bad case of wishful thinking [7]. To continue to indulge that fantasy [8] is to waste time and money [9]. It risks the credibility [10] and dignity [11] of UKBA [12]. Expectations are raised and can only be disappointed [13].

In summary, I put it to you that UKBA's faith in FRVT2006 is misplaced, I ask you to publish the results of UKBA's trials so far and I ask you to explain how an executive agency of the Home Office can fall into the trap of misleading the public.

Yours sincerely

David Moss


cc      Sir David Normington KCB, Permanent Secretary, Home Office

          Lin Homer, Chief Executive, UK Border Agency

          James Hall, Chief Executive, Identity & Passport Service

          Marek Rejman-Greene, Home Office Scientific Development Branch