By clicking 'Accept All Cookies', you agree to the storing of cookies on your device to enhance site navigation, analyse site usage, and assist in our marketing efforts.See our Cookies Policy.
Last updated: 12th December 2024
We currently use Live Facial Recognition Technology (LFRT) at our Palm Beach Casino (London), Resorts World Casino (Birmingham), Reading and Liverpool casinos. You can find posters on display in club providing more information and a link to these FAQs.
Genting Casinos UK Limited acts as independent Data Controller of personal data collected and processed through our use of LFRT, including for all biometric data. We are registered with the Information Commissioner's Office.
LFRT involves comparing a person's unique facial features against a database to identify 'persons of interest'. If you enter a Genting casino where LFRT is in use, cameras located at Reception and Cash Desk will scan your face to produce a unique biometric template. This is then compared against biometric templates held on the database. If there is a match to a 'person of interest', the system will alert our staff to your presence in the casino. A manager will then hold an interaction with you, and you may be asked to leave the premises depending on the circumstances.
We only use LFRT to identify the following categories of persons of interest, each of whom will have an entry on the database:
We do not make use of LFRT for any other purpose, nor will it be used to identify people outside of these groups.
The 'persons of interest database' is created by Genting using data from our existing casino management and security records. We use photographs of individuals within our existing records who are currently recorded as suspended / barred from Genting premises for responsible gambling reasons (including where SENSE enrolled) or further to the prevention or detection of crime, unlawful acts or disorder. We do not use data from other sources or from third party databases, such as commercially or publicly available databases or social media websites.
LFRT helps us to meet our legal and regulatory obligations to identify at risk individuals and to help keep our customers, employees and premises safe. Compared to manual procedures, LFRT offers a very accurate and efficient way of identifying persons of interest while reducing registration formalities, admin and queuing times for customers, particularly during open-door hours and busy periods.
Genting has identified the following lawful bases under the UK data protection laws (including the UK GDPR and Data Protection Act 2018) to support its use of LFRT for the purposes described above:
Genting has also carried out a detailed Data Protection Impact Assessment (DPIA) to support its use of LFRT and has reviewed the prevailing guidance on LFRT and biometric data processing from the ICO and the Biometrics and Surveillance Camera Commissioner.
The following types of data are collected or created as part of the end-to-end LFRT process:
In most cases, you will already know if you meet the criteria of a person of interest, i.e. you will know if you are currently SENSE enrolled, suspended / barred from Genting Casinos for responsible gambling reasons or for the prevention or detection of crime, unlawful acts or disorder.
If you know yourself to be a 'person of interest' based on the above criteria, we advise you not to enter the casino. Prominent signage is also on display at participating casinos to notify individuals that LFRT is in use before they enter the premises.
We need to screen all persons entering the premises against the database to check if a person of interest has entered. If there is no match, no personal data is retained and biometric templates are deleted immediately once the check has been carried out. In most cases, this means all biometric data has been deleted within seconds and, at the latest, within moments of you having left the casino at the end of your visit.
Many of our clubs now operate an open-door policy, meaning non-members are welcome to play without formal registration up to a threshold limit of £1,600. This means we may not have any personal data relating to you if you haven't visited us before. If you are a non-member who is suspended / barred following an open-door visit, we may review our CCTV images or the live-stream from the time of your visit to create an entry for you in the database. This is so that we can identify you via LFRT as a person of interest if you attempt to re-enter the casino in the future.
The LFRT software operates with a high degree of accuracy and has been subject to careful review by our third-party software partner during the development and testing stages. The specialist nature of the technology means it is much more accurate in recognising faces than manual, human methods of identification alone. We routinely review the performance of the software to verify the accuracy of its results and have policies and procedures in place to address discrepancies if and as they arise.
All biometric data is deleted as soon as the check has been carried out against the database. We apply the following retention periods for each part of the data collection process:
No. We can only tell if you are currently SENSE enrolled, suspended or barred from Genting premises due to responsible gambling reasons or for the prevention or detection of crime, unlawful acts or disorder. We cannot find out any other information about you through our use of LFRT.
Not usually. We may share limited amounts of data with our third-party software partner, the Face Recognition Company Limited, for maintenance and technology support, or with law enforcement agencies if we receive a lawful request for data for the purposes of the prevention or detection of crime. Data will only be shared if a legitimate request has been received from the relevant authorities in accordance with our Law Enforcement Data Access Request Policy and no biometric data will be shared due to the very short retention period. Otherwise, we do not share data collected using LFRT with anyone else or use it for any other purposes not listed in these FAQs.
We implement strict security protocols to safeguard personal data, including data collected or generated through our use of LFRT. All biometric data is held in a secure numerical format that cannot be easily reconstructed or decoded by third parties or machines. This means in the event of a data security incident, it is highly unlikely that anybody could identify you from this information alone. Our data retention policy ensures biometric data is erased within seconds of the check having been carried out which means there is very limited opportunity for this data to be compromised or misused even in the event of a data security breach.
No, all personal data is processed in the United Kingdom.
No. All alerts are manually reviewed by our casino management staff before an interaction takes place and individuals will be asked to provide ID before any decisions are made. This means we do not rely solely on automated means to make decisions about you if an alert is triggered by LFRT.
Your data subject rights, including the right of access and the right to make a complaint to the ICO continue to apply to our use of LFRT. You can find out more about your data protection rights, and how to exercise them here in the full Genting Casinos Privacy Notice. You can also contact our Data Protection Officer at DPO@gentinguk.com.
The 'right to object' under the data protection laws only applies in limited circumstances. Because we are using LFRT to meet our legal obligations, the right to object does not apply. Genting is committed to transparency around data protection and advises persons on entry that LFRT is in use. If you do not want to be subject to LFRT, we advise that you do not enter the casino premises.
Genting has partnered with a specialist third-party software partner in its use of LFRT. We recognise that there may be a small risk of bias in innovative technologies potentially leading to discriminatory outcomes for some demographic groups, particularly when being used live for the first time. For this reason, we have carried out thorough due diligence and testing of the software prior to live use to minimise this risk. The results of the software are also routinely reviewed to detect and address any unacceptable patterns of bias in its performance
These FAQs are designed to provide the necessary transparency information under the UK data protection laws to explain how we will collect and process personal data as part of our use of LFRT .
Genting is committed to transparency and welcomes ongoing engagement with our customers about our data protection practices - we'd love to hear you views and your feedback on our use of LFRT. We encourage comments, questions and feedback from customers, employees and visitors. You can find feedback cards on reception at participating casinos for this purpose. Alternatively, you can contact the Data Protection Officer on DPO@gentinguk.com
Last Reviewed: December 2024
Next Review Due: December 2025
Available on Android and iOS devices,
with our free to download app
*Full Badges T&C's here Full My Genting T&C's here
Download to start earning today!
Genting Casinos UK