The importance of process, policy and procedure

Brendan McGarrity, head of risk & design at Evolution, argues that new and developing technologies such as biometrics, facial recognition and Automatic Number Plate Recognition (ANPR) are only as useful, and effective, as the policies, processes and procedures that stand behind them: “This is where some businesses are potentially falling down,” he says.

“With ANPR, for example, the captured image of the vehicle’s number plate on its own does not contain any personally identifiable data. However, once the license plate is checked with the data held at the DVLA, then the ‘status’ of that data changes. It now enters a realm where the recently-introduced General Data Protection Regulation (GDPR) comes into play, and all of the challenges that brings.”

Brendan describes a similar scenario with facial recognition: “While it captures the image of a ‘living person’ and not an inanimate object, a policy, process and procedure remains a requirement in order to measure and manage the potential impact on privacy and – by definition – to support a compliant operation.”

Part of the challenge, Brendan says, is that whilst most firms are conversant with relevant safety regulations, and have the appropriate systems installed, it is easy for the integrity of those systems to be compromised: “Take fire,” he says. “We know the correct systems and equipment to install; we know they need to be well maintained and compliant with relevant Standards; we know the importance of an escape plan. But as soon as someone props open a fire door with an extinguisher, the integrity of the system collapses.

“The point is that you can have the best, most expensive system in the world, that delivers the highest levels of sophistication and modern thinking, but none of it is even worth the cost of the packaging if it does not have the correct policy, process and procedure in place to support and manage it.”

Brendan says that systems need to be adapted as a business changes – whether that’s security, HR, payroll or procurement: “Your people are your biggest strength – or your greatest weakness – depending on how you engage with them,” he concludes.

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