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Scottish Government launches consultation on future of biometrics oversight
Public invited to shape the next phase of the Scottish Biometrics Commissioner’s role as use of sensitive biometric data in policing continues to evolve.
The Scottish Government has launched a new public consultation seeking views on the future role and functions of the Scottish Biometrics Commissioner (SBC), marking an important moment in how Scotland governs the use of sensitive biometric data in policing and criminal justice.
Biometrics—such as DNA profiles, fingerprints, images, movement patterns and speech—are increasingly used to establish or verify identity. Because these characteristics are deeply personal, the law classifies biometric data as sensitive personal information. As a result, its use must strike a careful balance: supporting public safety while also protecting individual rights, privacy, and public trust.
To strengthen transparency and ethical practice, the Scottish Biometrics Commissioner Act 2020 created the independent office of the SBC. The Commissioner, appointed in 2021 and reporting directly to the Scottish Parliament, was tasked with promoting lawful, effective and ethical use of biometric data across policing bodies.
The SBC’s first four‑year strategic plan expired on 30 November 2025. Under Section 6 of the 2020 Act, Scottish Ministers must now prepare and publish a report on the Commissioner’s functions within one year of that expiry. To inform this report, the government is inviting views on two key questions:
- Are the SBC’s current functions still appropriate?
- Should any changes be made to the list of bodies under the Commissioner’s oversight?
Ministers are asking respondents to reflect not only on the impact the SBC has had so far in shaping ethical biometric practice, but also on the rapidly evolving landscape of biometric technologies within policing and criminal justice.
The consultation paper provides full background, including legislative context, the Commissioner’s remit, and emerging issues around biometric innovation.
Have Your Say
The Scottish Government is encouraging individuals, organisations, academics, justice partners and community groups to contribute their views.
Read the consultation and submit your response here
Your input will help shape how Scotland governs biometric data in the years ahead—ensuring public protection, ethical practice and public confidence remain at the heart of decision‑making.
