← Facial recognition in shops

Face Watchlist Agreement

Version 2026-10-02 · 2 October 2026 · AEY Vision

1. About this agreement

This agreement is between AEY Vision Limited (company number 17224921, 25 Pierston Avenue, Blackpool, FY2 9UT), which provides AEY Vision (“we”, “us”), and the business that accepts it in the AEY Vision console (“you”). It applies on top of the AEY Vision terms at aeyvision.com/terms, and where the two differ about the face watchlist, this agreement wins.

The face watchlist (the “Watchlist”) is a list of people shops using AEY Vision saw commit the incidents in section 4, and the comparison of faces at your chosen cameras, and on your intruder alarms, with it. You may use it only once you have accepted this agreement and done what section 6 asks.

For the Watchlist, you and we are joint controllers under UK GDPR Article 26. You are also controller of your own cameras and footage, and we remain your processor for the rest of AEY Vision as the AEY Vision terms say. The essence of this arrangement is published for the people it concerns at aeyvision.com/face-recognition.

2. What the Watchlist is for, and what it is not

The only purpose is preventing and detecting the incidents in section 4, to protect staff, customers and stock. Neither of us will use Watchlist data, or let it be used, for anything else, including:

  • marketing, customer analytics, counting, tracking or profiling;
  • monitoring, assessing or disciplining staff;
  • refusing entry or service to, searching, following, detaining or confronting anyone because of a match alone;
  • sharing with anyone outside the Watchlist, except evidence of a specific incident disclosed to the police or an insurer under a lawful basis of your own;
  • adding someone because of a grudge, a rumour, their appearance, or anything other than an incident in section 4.

3. Where it can be used

At shops in the United Kingdom only, open to the public, and only on cameras that cover entrances, tills or the shop floor — never toilets, changing rooms, staff rest areas or places outside the shop. It is not available at homes, offices or other premises.

4. Who may be added

You may add a person only after an incident at your business that your staff saw or that your cameras recorded, and only for:

  • theft worth £100 or more, or theft by someone who has stolen from your business before;
  • violence or assault;
  • threats or abuse towards your staff;
  • criminal damage or fraud.

Violence, criminal damage and fraud must have been reported to the police, with the crime reference given. You must not add anyone who appears to be under 18, or whom you have reason to think is vulnerable or was not responsible for what they did. The person adding them confirms each of these in the console, and the account of the incident they write must be accurate, factual and about what the person did, not how they look: the person may ask to see it.

We review every entry before other businesses are told of it. We may reject or remove any entry we think does not meet this section, and will tell you why. An entry lasts one year from the incident and is then deleted, unless a new incident is added.

5. Who does what

We will:

  • run the Watchlist and the comparison so that a face that matches nobody is discarded at the moment of comparison and never stored, and keep matching on systems we control;
  • review entries, keep them only as long as section 4 allows, and delete them when removed;
  • keep the appropriate policy document required by the Data Protection Act 2018 (Schedule 1, Part 4), our own data protection impact assessment for the Watchlist, and a record of every entry, review, match, decision and removal;
  • be the point of contact for people who ask about the Watchlist, answer their requests within the legal time limits, and tell you of any that concern your entries;
  • measure the Watchlist's accuracy, publish what we found, set the level at which a match is reported, and monitor decided matches for errors;
  • keep Watchlist data secure, in the UK and the EU, with access limited to the people who need it;
  • tell you without undue delay, and within 72 hours, of a personal data breach affecting Watchlist data, and notify the Information Commissioner where the law requires.

You will:

  • complete your own data protection impact assessment for the Watchlist at each shop (the compliance pack in the console has the section to use) and keep it under review;
  • put clear signs at every entrance, before the cameras' view, saying facial recognition is in use and pointing to aeyvision.com/face-recognition;
  • brief every member of staff who receives matches on how they work and on section 7, before they receive any;
  • add people only as section 4 allows, and keep your account of each incident accurate;
  • send us, within 3 working days, any request or complaint about the Watchlist you receive, and give us what we reasonably need to answer it;
  • tell us at once if you think an entry you added is wrong, and remove it;
  • pay the ICO data protection fee if your business must, and comply with data protection law for your cameras and footage.

6. Before switching it on at a shop

The console asks you to confirm, for each shop, that its impact assessment is completed and signed, that the signs are up, and that staff have been briefed. It records who confirmed each and when. Do not confirm anything that is not true.

7. Matches

A match is a possibility, not a finding. The software never makes a decision about anyone: a member of your staff compares the face seen with the face on the Watchlist and decides whether it is the same person. Where the law requires it, two people must agree. Nobody may be approached, searched, refused service, followed, detained or accused because of a match alone; if the person is the same, your staff follow your usual procedures for preventing crime and keeping themselves safe, and call the police if an offence is committed.

Mark each match as the same person or not. A match marked not the same person is deleted at once; every match is deleted after 30 days.

8. Security and confidentiality

Keep Watchlist information confidential and within the people who need it to act on matches. Do not copy, photograph, print, post or circulate faces or entries from the Watchlist, including in staff groups or with other businesses. Accounts with access to the Watchlist must be personal, not shared.

9. Misuse

If we reasonably believe the Watchlist is being used against this agreement, we may suspend it for your business, remove entries you added, and end this agreement, and we will tell you why. We may report serious misuse to the Information Commissioner.

10. Responsibility

Each of us is responsible for its own breaches of this agreement and of data protection law. You are responsible for the entries your business adds and for what your staff do about matches, and you will indemnify us against claims, fines and costs that arise from an entry added, or a match acted on, in breach of this agreement. Otherwise the limits of liability in the AEY Vision terms apply. Nothing limits liability that the law does not allow to be limited, or either party's responsibility to the people concerned under UK GDPR Article 82.

11. Ending

You can switch the Watchlist off at any shop at any time, and end this agreement by switching it off everywhere and telling us. When the agreement ends, matches at your shops are deleted, and entries your business added are removed within 30 days unless we agree with you that they should stay until they expire. Sections 2, 5 (as to requests about your entries), 8 and 10 continue to apply.

12. Changes

We may change this agreement, for example when the law or regulators' guidance changes. A new version is shown in the console, and the Watchlist stays available only once it has been accepted. This agreement is governed by the law of England and Wales, and the courts of England and Wales have exclusive jurisdiction.