North Ayrshire school meal payment verification

Occurred: October 2021

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In October 2021, nine schools in North Ayrshire, Scotland, started taking payments for school lunches by using facial recognition to scan the faces of pupils at the cash register in order to deduct money from an online account, according to the Financial Times.

CBD Cunninghams, the company that developed the system, claimed it speeded up queues and protected students better against COVID-19 than the card payments and fingerprint scanners the schools used previously.

Privacy advocates responded by saying the new system is not needed, operated without explicit consent, and amounted to the de facto normalisation of facial recognition.

The North Ayshire Council (NAC) programme was suspended after the UK Information Commissioner’s Office (ICO) responded to the controversy by encouraging schools to take a 'less intrusive' approach where possible. 

In February 2023, the ICO informed (pdf) NAC that it 'is likely to have infringed data protection law'. The ICO has published a case study on the incident.

Operator: North Ayrshire Council (NAC)
Developer: CRB Cunninghams
Country: UK
Sector: Education
Purpose: Verify meal payments
Technology: Facial recognition
Issue: Appropriateness/need; Privacy
Transparency: Privacy

Page info
Type: Incident
Published: October 2021
Last updated: February 2023