Do the French authorities know what I look like?

Karen Bollard, Senior Consultant


Thanks to the acknowledged benefits of remote working, I was able to write this article while in France to attend the group-stage matches as Ireland took on their opponents in the Rugby World Cup.

Worked up by all the hype and speculation that France would be using facial recognition at and around the stadiums used to host the Rugby World Cup 23 ( RWC23) matches, I fully expected to be bombarded by CCTV notices with every other step I took.

What led to all the hype and speculation?

  • Feb 2019: Nice becomes the first French city to start trialling facial recognition tools in its streets as part of a large-scale experiment. [1]
  • Nov 2019: CNIL (Commission Nationale de l’Informatique et des Libertés – the French DPA) publishes its advice on Facial Recognition, calling for public debate on the use of the technology, and recommending a use-by-use approach be applied to each implementation along with consultations on any implementations carried out for test purposes [Nice did not consult the CNIL before rolling out its trial in February].[2]
  • May 2023: French courts approve the use of AI Surveillance for the Olympics in 2024 (albeit without the use of biometrics).[3]
  • June 2023: the French Senate, the upper house of the French parliament, agrees to adopt a draft law on testing facial recognition technology in public spaces. This law allows judicial investigators and intelligence services to use remote biometric identification in public for the forthcoming three years.[4]
  • Sept 2023: French authorities state that they will boost security at the Stade de France for the Rugby World Cup as a result of lessons learned following the crowd security fiasco of the Champions League Final in May 2022. These enhanced measures include an increased police presence and improved ‘video protection systems’.[5]

What did I actually encounter in France?

The main thing I saw was members of the Gendarmerie patrolling in plain sight while armed to the hilt. I also saw what I assume was an army squad in Nantes (dressed in khaki and bearing machine guns). I even found a member of the Gardaí (Irish police) accompanying some of the local gendarmes. So, it would appear that the authorities lived up to their promise of providing an increased police presence.

I also saw lots of CCTV cameras, as one would expect given the plan for increased surveillance ‘video protection devices’ in and around the stadiums. However, despite my best efforts I did not find a single privacy notice warning me about the use of Facial Recognition – nor any notices that normal CCTV monitoring was in operation (even on the police headquarters). Believe me, I tried.

In fact, the only CCTV notices I found during my trip were not close to the stadiums at all but were posted by businesses with a genuine interest in privacy transparency – The Louvre, the transport systems, secure carparks, building sites etc.

  1. These observations suggest that several questions must be asked: Did the authorities crumble in the face of mounting international public concern about how Facial Recognition Technologies (FRTs) and AIs are trained to recognise individuals, and not deploy the 'improved video protection systems' after all?
  2. Did they consider the inherent racial bias, reduced effectiveness of identifying women and ethnic minorities or the fact that AI matches are based on probabilities and that false positives can and do occur, and decide not to use them?
  3. Did they feel that France (or the world) was not yet ready for full AI and FRT surveillance and roll back their plans?
  4. Or did they implement FRTs but choose to carry out the processing solely under Article 10: processing of personal data relating to criminal convictions and offences? Or perhaps under derogation as a matter of Social Protection Law Article 9.2(b)? While also ignoring their transparency obligations under Article 12?

In other words, do the French Authorities know what I look like? I think that they might – but I truly hope that they don’t. Because if they do then a variant of option 4 is almost certainly what occurred.

And one of my key fears regarding the use of FRT is the slowly creeping normalisation of surveillance in our society – a threat to our privacy that we should all be aware of and guard against. Which is very hard to do, if it’s being done without our being told.



[3] Biometric Update
[4] (
[5] The Guardian

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