Marek Rejman-Greene

Senior Biometrics Advisor

Home Office Scientific Development Branch (HOSDB)

c/o Direct Communications Unit

2 Marsham St

London SW1P 4DF


Your ref. T21200 8
2 January 2009


Dear Marek

Biometrics based on facial recognition

Thank you for your letter dated 14 October 2008.

To recap, after all this time, our correspondence concerns the facial recognition biometrics trial currently being conducted at Manchester airport [1]. The correspondence began with my email to you dated 21 August 2008 [2]. There have been other communications in between [3], [4], [5] and [6].

There is a lot of literature about mass consumer biometrics available in the public domain [7], including the feasibility study undertaken by you and Tony Mansfield [8]. Most of this literature suggests that mass consumer biometrics are unreliable, and none more so than biometrics based on facial recognition as you and Tony Mansfield say:

Biometric methods do not offer 100% certainty of authentication of individuals ... Even under relatively good conditions, face recognition fails to approach the required performance ... With the known performance of fingerprint, iris and face biometric systems, this requirement mandates the use of multiple fingers, or irises, and confirms that facial recognition is not a feasible option ... Face recognition is not strong enough to uniquely identify one person in a population of 50m.

Which is why I suggested in my 21 August 2008 email to you that the case should be made, publicly, for biometrics based on facial recognition. Anyone familiar with the literature will otherwise be mystified at this apparent waste of taxpayers' money in Manchester on a technology which will do nothing to protect the UK's borders.

According to the BBC [9], 19 August 2008, the Public and Commercial Services union (PCS) have raised security concerns about relying on biometrics based on facial recognition. And according to the Daily Telegraph [10], 4 October 2008:

Sources from the UK Border Agency (UKBA) have revealed that the devices are failing to detect when two people pass through them at the same time.

The system, which replaces traditional passport control measures, is undergoing a "live trial" at Manchester Airport, where a UKBA worker said it was suffering almost daily malfunctions.

He said immigration officers had been able to accompany travellers through the scanners without an alarm being triggered, even though the booths are supposed to detect if more than one person enters at a time.

"Immigration officers have been able to tailgate passengers through the machine, without the machine picking it up," he said ...

The source said there were malfunctions taking place almost daily in the pilot project, which is thought to have cost the taxpayer several hundred thousand pounds.

"There are five 'pods' and when one breaks down, they all break down," he said ...

The UKBA source said there were widespread concerns about the facial recognition equipment.

"There is no reliable data on the machine's ability to pick up forgeries and imposters," he said ...

A spokesman for the PCS union, which represents UKBA staff, said: "The notion that you can replace the human intuition of highly trained immigration staff with unproven machines is dangerous.

"The technology is further undermined by staff sitting in front of the monitors for three hours at a time, leading to mental fatigue and a drop-off in concentration. There are major concerns about the reliability and accuracy of facial recognition technology ...

"We have advised our members not to train to use the equipment or to man it" ...

"Up until the point of the official launch, it was rejecting 30 per cent of those who tried to get through it," the UKBA worker said.

"We believe they had to recalibrate it essentially make it easier to get through the system."

It is essential that someone make the case to the public in favour of this technology. I assume that that is your job at HOSDB. None of the replies received from HOSDB so far addresses this point. Will someone now explain to the public why taxpayers' money is being spent on a technology which has such a poor record?

That is the main reason I contacted you. You have answered many other points, for which thank you, I will return to those in a separate letter, but here the point is to repeat my request to you/HOSDB to explain to the public why taxpayers' money is being spent on an apparently hopeless and discredited technology which cannot possibly protect the UK's borders.

Yours sincerely

David Moss