Within a year, India could have the world’s largest facial recognition system in place. Yet, there has been little or no debate about safeguards for such a system within India’s parliament, and many privacy advocates both inside and outside the country are already warning about the potential privacy and surveillance issues involved. According to India’s National Crime Records Bureau, which is organizing bids for this proposed facial recognition system, the chief aim is modernizing the police force and making it easier to catch criminals and track down missing persons. But there is a very real risk that such a system could transform India into the world’s largest surveillance state.

How the facial recognition system will work

As outlined in a 172-page bid document prepared by the National Crime Records Bureau, the new facial recognition system must meet a number of important guidelines. First and foremost, it must be able to recognize images from a diverse range of sources, such as CCTV cameras, mobile handheld devices used by Indian law enforcement officers, and even photos from local newspapers. Secondly, the facial recognition system needs to be integrated into the various criminal databases used by Indian police stations, such that it becomes much easier to find, track or apprehend suspects anywhere in the country. Moreover, the new facial recognition system must be able to compensate for any of the various factors – such as plastic surgery, scars, beards, or tattoos – that might be used by criminals to obscure their appearance.

The scale and scope of the new facial recognition system, as might be imagined, is massive. It will apply to all 29 states and 7 union territories of India, and will eventually be scaled up to include images of all 1.3 billion people living in India. It will also likely require rapid deployment of CCTV cameras across India, especially in densely populated urban centers. For example, India only has 10 CCTV cameras per 1,000 citizens in New Delhi. By comparison, there are 68 CCTV cameras per 1,000 people in London and 113 per 1,000 in Shanghai. So Indian citizens can count on the sudden appearance of cameras all around them – on busy streets, in shopping areas, and in any high-density population area where crime might be an issue.

Surveillance concerns about facial recognition

Understandably, privacy advocates such as Apar Gupta, Executive Director of the Internet Freedom Foundation, are concerned that a system designed primarily for safety and security might be abused. Gupta says that details about the facial recognition system are sketchy at best – it’s not even known how many bidders actually applied to build such a system for India. In addition, it is not clear where it will be deployed; how data will be used, collected and shared; or how data storage will be regulated.

And such a facial recognition system might be used in other, unknown ways. There are already plans afoot, for example, to unite this facial recognition system with all of the other ways that the Indian state already has to track its citizens. Most notable of these is the nation’s Aadhaar program, a national biometric ID card program. There is also talk of building a so-called “National Intelligence Grid” linking data from the worlds of banking, finance, taxation and travel with facial recognition data. At a moment’s notice, an Indian police officer in any of the nation’s 29 states might be able to pull up information about a citizen or perform a facial recognition scan – perhaps without the knowledge or consent of the citizen. There also have been efforts discussed within India to link Aadhaar biometric data with social media account data. Imagine algorithms powered by artificial intelligence scanning social media photos for people, all without their knowledge.

India has been pushing the use of facial recognition data at points of travel, such as airports. The “Digi Yatra” (“Digital Journey) experience, for example, makes it much easier to check in with your face when boarding an airplane at Indian airports. Instead of presenting a formal ID card, airline passengers simply consent to have their faces scanned. If there’s a match, then the passenger gets to board the airplane. According to Indian authorities, such a system might be easier and more efficient than the one being used now, and it might also be able to catch a suspected terrorist before he or she ever boards a plane.

Worrisome signs in India

However, one big problem in India is that, quite simply, the country lacks any kind of personal data protection law that applies to individual citizens. While the nation’s Supreme Court has ruled that privacy is a fundamental human right, there are no rules about how data can be used in India, or even if certain entities need to ask for consent when using surveillance images. That’s why advocates such as Vidushi Mardi, a lawyer and researcher for Carnegie India and Article 19, a British human rights organization, suggest that the facial recognition system has the potential to become a “mass surveillance system” operating in public view. In a worst-case scenario, it might be used for social policing and control.

That risk of increased surveillance, of course, bring up another major problem: the nation’s policy toward ethnic minorities, especially Muslims and darker-skinned citizens in southern India. The current Hindu nationalist politicians supporting Prime Minister Narendra Modi suggest that any surveillance program might be used to crack down on the nation’s Muslim population. But could it be used to round them up and then send them to mass detention camps where they could be watched even more?

And don’t forget about the national security concerns, either. The bidding process specifically requires any winner to have had experience with at least three facial recognition projects around the world. That almost guarantees that a foreign surveillance company already active within India will walk away with the winning bid. So does that mean that foreign nations will also have access, albeit indirectly, to Indian facial recognition data? And where will all the CCTV cameras come from? One of the largest CCTV vendors active within India, Hikvision, is a Chinese company.

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India needs to stop rushing forward with facial recognition tech

Given all of these factors, it’s easy to see why so many people – especially privacy advocates and human rights activists – think that India is rushing headlong into a massive new facial recognition project without giving it a lot of care and attention in advance. There’s a reason why municipalities around the globe – such as San Francisco, which has banned facial recognition technology – are pushing back against the spread of facial recognition technology. Privacy is a fundamental human right, and not something that should be overlooked in the name of greater security.