Italy wins: DPA blocks facial recognition system and MP proposes moratorium

By Laura Carrer (research & advocacy – Italian campaign lead organisation Hermes Center, and Riccardo Coluccini – Italian campaign contributor)

On Friday 16 April, the Italian Data Protection Authority (DPA) rejected the SARI Real Time facial recognition system acquired by the Police. The DPA argues the system lacks a legal basis and, as designed, it would implement a form of mass surveillance. Two days earlier, on 14 April, a member of the Italian Parliament, Filippo Sensi, proposed a moratorium on the use of video surveillance tools that use Facial Recognition.

The Automatic Image Recognition System (SARI) was initially acquired by the Italian police in 2017 and, according to the police, the real-time version has never been used. The system was under investigation by the DPA since November 2017, after a news article prompted the Authority to open an investigation, and Hermes Center’s pressure for the Authority to promptly conclude this investigation. Recently, this system was at the center of a new public tender with the aim of upgrading, and employing it to monitor arrivals of migrants and asylum seekers on the Italian coasts.

The recent opinion published by the Italian DPA highlights the fact that “SARI Real Time would carry out a large-scale automated processing of data that may also concern people attending political and social events, who are not the object of ‘attention’ by the police forces.” In addition, the Authority points out that although in the data protection impact assessment “the Ministry explains that the images would be immediately deleted, the identification of a person would be achieved through the processing of biometric data of all those present in the monitored space, in order to generate patterns comparable with those of the subjects included in the watch-list.”

“SARI Real Time would carry out a large-scale automated processing of data that may also concern people attending political and social events, who are not the object of ‘attention’ by the police forces.[..]”

The Authority adds that this kind of biometric surveillance would signal a shift “from targeted surveillance of few individuals to the possibility of universal surveillance for the purpose of identifying certain individuals.”

According to the Italian DPA, right now, the Ministry of Interior lacks a legal basis that would allow processing of this kind of biometric data as collected and analyzed by SARI Real Time, thus the MoI cannot use this live facial recognition system. 

The DPA also pointed out some critical aspects to be taken into account for any future attempt to regulate similar live facial recognition technologies. The Authority stressed the importance of the “criteria for identifying the subjects who can be included in the watch-list or those for determining the cases in which the system can be used” and the “possible consequences for the interested parties in case of false positives”—including also concerns towards people belonging to ethnic minorities.

In addition, on Wednesday, April 14, facial recognition entered the Italian political debate. Italian deputy Filippo Sensi presented a new legislative proposal for a moratorium on the use of facial recognition technologies in public spaces, both by public and private actors. In the proposal, reference is made for a suspension until December 31, 2021 pending the introduction of an adequate national legislative framework to regulate the use of such technologies. Although the Hermes Center considers such a short timeframe inadequate and would also like to see all sorts of biometric surveillance technologies included in the law, we welcome this legislative attempt and we will closely follow its developments.  

Italian deputy Filippo Sensi presented a new legislative proposal for a moratorium on the use of facial recognition technologies in public spaces both by public and private actors.

On Saturday, April 17, during the TV program “Progress” aired on SkyTg24, Hermes Center was a guest together with a member of the board of the Italian DPA, the deputy Filippo Sensi, and Privacy Network, an Italian association that supports the RYF campaign. During this programe, we obtained further assurances. Based on the opinion of the DPA on SARI Real Time, we have been assured that the 287 municipalities that have received funding from the Ministry of Interior to install new video surveillance systems will not be able to use biometric technologies. 

The Hermes Center firmly believes that:

  • In Europe, biometric mass surveillance must be banned from our public spaces;
  • There shouldn’t be any exceptions for systems used by police authorities


ReclaimYourFace is a movement led by civil society organisations across Europe:

Access Now ARTICLE19 Bits of Freedom CCC Defesa dos Direitos Digitais (D3) Digitalcourage Digitale Gesellschaft CH Digitale Gesellschaft DE Državljan D EDRi Electronic Frontier Finland Hermes Center for Transparency and Digital Human Rights Homo Digitalis IT-Political Association of Denmark IuRe La Quadrature du Net Liberties Metamorphosis Foundation Panoptykon Foundation Privacy International SHARE Foundation
In collaboration with our campaign partners:

AlgorithmWatch AlgorithmWatch/CH All Out Amnesty International Anna Elbe Aquilenet Associazione Luca Coscioni Ban Facial Recognition Europe Big Brother Watch Certi Diritti Chaos Computer Club Lëtzebuerg (C3L) CILD D64 Danes je nov dan Datapanik Digitale Freiheit DPO Innovation Electronic Frontier Norway European Center for Not-for-profit Law (ECNL) European Digital Society Eumans Football Supporters Europe Fundación Secretariado Gitano (FSG) Forum InformatikerInnen für Frieden und gesellschaftliche Verantwortung Germanwatch German acm chapter Gesellschaft Fur Informatik (German Informatics Society) GONG Hellenic Association of Data Protection and Privacy Hellenic League for Human Rights info.nodes irish council for civil liberties JEF, Young European Federalists Kameras Stoppen Ligue des droits de L'Homme (FR) Ligue des Droits Humains (BE) LOAD e.V. Ministry of Privacy Privacy first logo Privacy Lx Privacy Network Projetto Winston Smith Reporters United Saplinq Science for Democracy Selbstbestimmt.Digital STRALI Stop Wapenhandel The Good Lobby Italia UNI-Europa Unsurv Vrijbit Wikimedia FR Xnet

Reclaim Your Face is also supported by:

Jusos Piratenpartei DE Pirátská Strana

MEP Patrick Breyer, Germany, Greens/EFA
MEP Marcel Kolaja, Czechia, Greens/EFA
MEP Anne-Sophie Pelletier, France, The Left
MEP Kateřina Konečná, Czechia, The Left

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