Is it ethical to implement site-wide facial recognition technology without informing all employees?

Question

Background

I am a very junior researcher working at a government research institution that, alongside R&D, hosts lots of educational courses. Due to presence of potentially sensitive data, biometric and other security restrictions are present; most of which are handled by inhouse IT. Recently, there have reliability issues with our security solutions, and until new tenders and contracts were laid out, we were asked to brainstorm some intermediate (preferably cheap) measures. Also of note, the entire campus is under (usually multiple) camera surveillance at all times.

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Problem

During discussion, me and a colleague had brought up small-scale facial recognition technology (FRT) as a long term prospect. We were asked if there were open source solution and I suggested OpenFace (by Carnegie Mellon University). Management was very interested and asked IT to deploy it in campus as a separate project and to use it as a way for tracking everyone on campus at all times. I had registered my protest at this being a possible privacy violation at the time, but nobody else seemed concerned.

Later, my colleague was separately informed that she and I were strictly not to inform anyone on campus. She was also told look over the implementation and give recs if necessary.

The problem is, I think FRT can be irresponsible and can be a violation of privacy unless handled very carefully. Even OpenFace's readme makes this very point. None here shares my POV, and I'm kind of at a loss as to what to think. I can bring it up to higher authorities, but I'm very, very junior and don't want to make a mess about something trivial. My initial suggestion had been purely to implement FRT while entering highly sensitive rooms like server racks/satellite control centers/etc.

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So, is it ethical to implement such wide-spread face recognition, possibly violating privacy, without informing users? If not, what can I do about it?

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PS

Also, I'm in India, if that helps. And I know that there are no strictly legal objections.

Answer 1

If I understand you correctly, the new thing would be that you build a database of everyones movement across the campus. This is different from having CCTV or guards in place, as previously the data of who is at which place and what time was not aggregated this way before.

Here's the ethical concerns I see:

• It does not seem to solve the problem: Presumably, the sensitive information is 'present' in some rooms on some machines etc. You need to stop people from getting where they are not supposed to be. Why is knowing that X went from room 1 to room 2 along hallway 3 and taking a bathroom break along the way a solution to your problem

• Data tends to get used. Even if there are no concrete ideas what to do with all the data on who moves where now, there will be. This needs careful consideration. Maybe they'll skim this data for people who spend 'too much' time smoking or on the toilet. You know more about your campus, give this some thought.

• They want to keep it secret. Did everyone on the campus consent to have all their movements logged? In all likelhood not, so this is clearly unethical, even if legal.

Answer 2

Whether something is ethical or not is always also based on the culture you are in. As I don't know the culture in India, I can only tell you the culture in Germany.

For a data collection to be ethical, it must follow some core requirements:

1. Appropriation
   It must be known what the data is used for and what the point of the data collection is. As far as I can tell, this requirement is not fulfilled. How this face tracking data is going to be used and what the purpose is, is unknown.

2. Reduction
   The data you collect must be limited to the amount that is necessary to fulfill the purpose and there is no data already available somewhere that you can re-use. For example, if there is an incident and the existing camera footage shows the face of the person, why do you need to identify all other persons that have nothing to do with the incident? It would be sufficient to let the face recognition software run on the few seconds of the incident and maybe a few minutes before to identify witnesses. But that's it.

3. Necessity
   The data you collect and the way you collect it, must be necessary. It must be in proportion to the desired purpose. For example, to measure how much time a student spends on the toilet, you do not need a camera in the stall, although it would work; but there are other less intrusive methods to measure time, so the camera footage is not necessary.

Answer 3

Here's the quote from OpenFace:

We do not support the use of this project in applications that violate privacy and security. We are using this to help cognitively impaired users to sense and understand the world around them.

The issue isn't that the project ITSELF violates people's privacy, but how it is used. You can use camera for perfectly legal and respectable purposes, and obviously NOT legal and invasive purposes.

I believe one way to use it that violates privacy is to use it to scan data on the internet, grab the embarrassing photos of a particular person, and use this data to attack them.

HOWEVER! Your superiors are thinking about something that causes them to tell you not to tell anyone. If their purpose is simply security, why were they unable to provide the arguments presented on SE by complete strangers? We do not have access to what your superiors are thinking, but it may be useful to tread with care and protect yourself from anything illegal. Get written specifications as to what it is for, and get legal sign-off on them. You don't want to position yourself as a scapegoat.

Answer 4

I don't see why it would be unethical, people are already on camera, this is just manipulation of existing data. It's benefits in terms of security are easy to identify. I don't see any basic difference than having security personnel watching the camera views which is commonplace in many businesses.

Answer 5

If the data from the face recognition detectors are sent outside the campus, then the issue needs to be discussed upon. Both with the people inside the campus, the management and the ethics committee of your institute; as the privacy of people is at stake here.

But, if the data remains in-house, and used just for surveillance by the in-house guards, etc; then I don't see any difference between the existing technology and the present one, in terms of privacy intrusion. So, if this is the case, you can go ahead and implement it.

Answer 6

Please be careful. It appears you are alone with your views. "Making waves" by bringing this up with HR, the union or anyone else could backfire. My impression is no one will appreciate your concerns and the people directly involved may very well consider you to be a troublemaker.

Also, you have been explicitly told to not tell anyone:

Later, my colleague was separately informed that she and I were strictly not to inform anyone on campus.

Personally I would try to anonymously leak this information to third parties, e.g. the students council. But that is also a very risky choice because it may be possible to track this back to you, so I would not recommend this.

Perhaps you can raise other issues (e.g. too much data to process if implemented in large scale) or implement it in a way which makes sense from security POV.

Please check if the company you are working at shares your core values (apparently it does not, at least the people who you are working with). If acting ethical is important to you, it may not be a good fit - as has been blatantly revealed. You may want to stay on, to gather experience, but long term, I would look for a workplace which better fits your values.

Apart from that - as already stated - the plan makes little sense and better security for those specific areas would be a better choice. As has also been stated, from data protection point of view, only collect the data you actually need, not "all of it" or "as much as possible".