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CBSE rebuffs need for privacy policy of facial recognition tool: ‘it’s a simple face matching process’

Government-run education board CBSE said its facial recognition system does not have a privacy policy because it is a “simple face matching process”, the board said in an RTI filed by Delhi-based digital rights group SFLC.in.

CBSE or the Central Board of Secondary Education had rolled out a facial recognition system in October for students to download their academic documents for the 10th and 12th grade. More than 2,300 students had gone through the facial recognition tool, as of November 24, to download their documents, CBSE said in the RTI. MediaNama had earlier reported that CBSE’s facial recognition system doesn’t have enough safeguards, including a privacy policy.

There’s a major gap in CBSE’s response: It isn’t clear what the organisation means by a “simple face matching process”, and why that is enough of a reason to not have a privacy policy. Students’ photographs, collected by the CBSE to issue board admit cards, form the basis of the facial dataset that underpins this facial recognition system, which means that the organisation will be dealing with sensitive personal data of children.

It also isn’t clear if the CBSE’s facial recognition tool uses the 1:1 or the 1:N protocol. The former verifies an image against another image, while the latter recognises an image from a large dataset. In either case, facial recognition technology, in general, isn’t a simple technology to get right, and it appears that the central education board is trying to significantly downplay the capabilities of its facial recognition system.

CBSE, in the RTI response, also said that the facial recognition functionality is currently under a pilot phase and is “just a second factor facial matching verification service”.

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CBSE won’t say if it carried out a privacy impact assessment: SFLC.in had also asked CBSE whether it had carried out a privacy impact assessment before rolling out the facial recognition tool, and CBSE did not directly address that question. Instead, it said that “no template consent form” was created.

No additional consent sought from students or guardians: CBSE also revealed that it has not sought any additional consent from students or their guardians for using the facial recognition tool because no additional data is needed by the system. “The system uses the admit card photographs already available on CBSE record to match the photograph of the student,” it said.

However, we had earlier pointed out that it isn’t clear whether CBSE had intimated students and guardians that the photographs they’re submitting for their board certificates could someday be used as a facial dataset.

CBSE claims extremely high accuracy rates: CBSE also claimed that the accuracy of its “simple face matching” tool is 99% in “test conditions”. This is a very high accuracy rate, and is only possible in the most ideal scenarios, where every component including the camera, and lighting is controlled. In real life scenario, a lot of students will actually be using the system using low quality webcams on laptops, which is bound to reduce the system’s accuracy.’

‘No private company involved’: CBSE said that the system was developed in “technical collaboration” with the National e-Governance Division, under the IT Ministry. However, it did not specify what role NeGD played in the development of the platform, and whether any other entity was involved in its development. However, it did specify that no private company was involved in the development of this tool, or any of its features.

Read more from our coverage related to facial recognition:

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