This week, a coalition of human rights and privacy organizations, including the **EFF**, **Foxglove**, and **Human Rights Watch**, formally addressed **Alex Norris**, the UK’s Minister of State for Border Security and Asylum. Their letter expresses deep apprehension about the Home Office's decision to deploy Facial Age Estimation (FAE) technology to assess the ages of asylum-seeking children. ### Discrimination Concerns Mount Critics point to inherent biases within FAE and similar facial recognition tools. Evidence suggests FAE systems are more accurate for Eastern European men, yet still produce errors. The Home Office's own documentation acknowledges that "FAE performance can vary depending on ethnicity" and skin tone, raising flags about potential discrimination against women and people of color among asylum seekers. ### Inaccuracy Where It Matters Most The Home Office has admitted that FAE systems are imprecise for the critical 16-to-18 age range, the very group targeted by this technology. Even "top systems" reportedly have an "error margin of around 2.5 years." This margin could be further exacerbated by trauma-induced aging often experienced by child asylum seekers, leading to potentially life-altering misclassifications. ### Lawfulness of Children's Data in Question Significant legal and ethical questions surround the collection and processing of data from asylum-seeking children. There is a lack of clarity on the lawful basis for obtaining consent to collect photographs or data from these vulnerable individuals, or for the training of the FAE system by the Home Office or its third-party vendors. Furthermore, details regarding the images and data used for training remain undisclosed. ### Lack of Transparency and Disclosure The Home Office asserts that "extensive testing has already been carried out across diverse groups, including different ethnicities, genders and age ranges, indicating promising performance and accuracy." However, these "promising" results have not been publicly released, nor have any Equality or Data Protection Impact Assessments. This lack of transparency undermines trust and prevents independent scrutiny of the system's efficacy and fairness. The coalition has given the UK government 21 days to respond to their concerns and release the requested information. They urge the Home Office to address these critical issues in good faith.