Law · United Kingdom
Is face search legal in the United Kingdom?
In the United Kingdom a face template is special category data under UK GDPR, so an engine needs explicit consent or another Article 9 condition to build one. Searching your own face is lawful, and checking a person you are dealing with is an ordinary purpose; what the law restricts is stalking, harassment, image abuse and using a match to make decisions about someone. Whether the ICO can reach a foreign engine is the question the Clearview AI appeal will decide.
First search free. No account needed. Updated November 6, 2026 by The FaceSearch Team.
The UK kept the GDPR after leaving the EU as the UK GDPR, read together with the Data Protection Act 2018, and the Information Commissioner's Office (ICO) enforces both. For face search that means the same core rule as in Europe: extracting a face template to identify someone is processing special category data, which needs explicit consent or another narrow condition. Around that sit the criminal offences that apply to people who misuse what they find, and a regulator for platforms, Ofcom, that did not exist in this role before 2023. This page extends the overview on is face search legal with the UK detail as of November 2026.
What does UK GDPR say about face templates?
Article 9 of the UK GDPR prohibits processing biometric data for the purpose of uniquely identifying a person unless one of the Article 9(2) conditions applies, and Schedule 1 of the Data Protection Act 2018 adds the UK-specific conditions. The ICO's Biometric data guidance: Biometric recognition, published in final form on 23 February 2024, says that running a biometric recognition system means processing special category data from the moment of collection, that explicit consent will usually be the only workable condition for a commercial deployment, and that a data protection impact assessment is required before the system is used. An engine that builds templates from scraped photos of UK residents has none of that, which is why the ICO's dispute with Clearview AI has run since 2021.
Can the ICO act against an engine based abroad? The Clearview AI case
| Date | Step | Outcome |
|---|---|---|
| May 2022 | ICO monetary penalty and enforcement notice | Fine of about GBP 7.5 million; ordered to stop collecting UK residents' data and delete what it held |
| October 2023 | First-tier Tribunal | Fine and notice set aside: the ICO lacked jurisdiction because Clearview served only foreign law enforcement |
| October 2025 | Upper Tribunal | First-tier decision reversed on three of four grounds; Clearview's processing amounted to monitoring UK residents' behaviour, so the ICO had jurisdiction; case sent back to the First-tier Tribunal |
| December 2025 | Permission to appeal | Clearview granted permission to appeal to the Court of Appeal |
| October 2026 | Court of Appeal hearing | Three-day hearing from 19 October 2026; judgment reserved |
The case matters beyond Clearview. If the ICO's jurisdiction over a company with no UK office is confirmed, every face search engine that indexes UK residents is within reach of UK GDPR enforcement, wherever it is based.
Is it legal to search for someone else's face in the UK?
Running a search is not an offence. The Protection from Harassment Act 1997, with the stalking offences added by the Protection of Freedoms Act 2012, criminalises a course of conduct that amounts to harassment or stalking, and monitoring a person's online activity is one of the listed examples. Using a face search to locate, follow or repeatedly contact someone who does not want contact is the kind of conduct those offences cover. Publishing what you found can engage the Malicious Communications Act 1988 and, for private information, the civil law of misuse of private information. Using a match to decide whether to employ, house or serve someone engages UK GDPR's fairness rules and, where a protected characteristic is involved, the Equality Act 2010. None of this prevents the ordinary check that someone you are about to meet or pay is who they say they are; see verify someone is real.
Which offences cover intimate images and deepfakes?
- Sharing an intimate image without consent. Section 66B of the Sexual Offences Act 2003, inserted by the Online Safety Act 2023 and in force since 31 January 2024, makes it an offence to share or threaten to share an intimate image without consent. The base offence no longer requires proof of intent to cause distress; aggravated versions cover intent to cause alarm or distress and sexual gratification. It covers deepfakes of real people.
- Creating a sexually explicit deepfake. The Data (Use and Access) Act 2025 added an offence of creating, or requesting the creation of, a purported intimate image of an adult without consent. It came into force on 6 February 2026.
- Cyberflashing. Section 66A of the same Act, also from the Online Safety Act, covers sending unsolicited images of genitals.
- Platform duties. The sharing offence was made a priority offence under the Online Safety Act in 2024, so platforms must assess and reduce the risk of it on their services. Ofcom's illegal content codes, in force since March 2025, require providers to take intimate image abuse down when they become aware of it, and Ofcom added hash-matching measures for non-consensual intimate images in 2026.
If this has happened to you, the intimate image abuse page puts the Revenge Porn Helpline, StopNCII and the police route before any search tool.
Where do you report a fake profile or a scam?
Report the account to the platform first; the fake profile page has each platform's route. For fraud, including romance and investment scams, report to Action Fraud in England, Wales and Northern Ireland, or to Police Scotland on 101. If you think a company is processing your biometric data unlawfully, you can complain to the ICO after raising it with the company, and you can ask the ICO to consider complaints about engines based overseas; the Clearview case will determine how far it can act on them.
Searching your own face versus someone else's
| Your own face | Another adult's face | |
|---|---|---|
| UK GDPR | Exercising your own rights; no duty on you | Personal use is outside the regulation; publishing what you found is not |
| Article 9 biometric rules | Fall on the engine | Fall on the engine, not on you |
| Harassment and stalking offences | Not engaged | Engaged if you track, follow or repeatedly contact the person |
| Decisions about people | Not engaged | Fairness rules and the Equality Act apply to employment, housing and service decisions; FaceSearch prohibits these uses |
| FaceSearch policy | The core use | Allowed for checking who you are dealing with; no searches for anyone under 18 |
How does this apply to FaceSearch?
FaceSearch searches only publicly accessible pages and returns the pages where a similar face appears, with no names and no identity claims. Your upload is stripped of metadata, used only for your search and never used to build a face database, so your biometric data does not enter any index through us, and UK residents can be excluded from results for free by email through remove my photos. Our acceptable use rules ban the conduct the offences above describe and any employment, housing, credit or insurance use. We follow the ICO's biometric recognition guidance as the standard for how a UK engine should behave, and we update this page when the Court of Appeal rules.
Questions
01Is it legal to search for my own face in the UK?
Yes. Finding where your own image appears is a transparency right, not a restricted activity, and a private search carries no UK GDPR duties for you. FaceSearch is built around this use; the first search is free with no account.
02Is it legal to search for someone else's face in the UK?
A one-off check on a person you are dealing with is lawful. The law restricts what follows: a course of conduct that amounts to harassment or stalking, publishing private information, or using a match to decide whether to employ, house or serve someone. FaceSearch prohibits those uses and any search for a person under 18.
03Can the ICO fine a face search engine based abroad?
The Upper Tribunal said in October 2025 that it can, where the engine monitors the behaviour of UK residents. Clearview AI appealed and the Court of Appeal heard the case in October 2026. Until the judgment, the ICO's 2022 fine against Clearview is neither paid nor finally overturned.
04Someone shared intimate images of me. What is the offence?
Sharing or threatening to share an intimate image without consent is an offence under section 66B of the Sexual Offences Act 2003, in force since 31 January 2024, and it covers deepfakes. Creating a sexually explicit deepfake of an adult became a separate offence on 6 February 2026. Report to the police and to the platform, and use the Revenge Porn Helpline and StopNCII for removal.
05Where do I report a fake profile or a romance scam?
Report the profile inside the platform first. For money lost to a scam, report to Action Fraud in England, Wales and Northern Ireland, or call Police Scotland on 101. Keep screenshots of the profile, the conversation and any payment requests before the account disappears.
06Can my employer or landlord run a face search on me?
They can run a search, but using it to decide whether to hire, house or serve you engages UK GDPR's fairness and transparency rules and, where a protected characteristic is involved, the Equality Act 2010. FaceSearch's rules prohibit employment, tenant, credit and insurance uses outright.
Sources
- ICO: Guidance on biometric data (biometric recognition, final version February 2024)
- ICO: UK Upper Tribunal hands down judgment on Clearview AI Inc (October 2025)
- 11KBW: Upper Tribunal hands down Clearview v ICO judgment on territorial and material scope of GDPR
- PPC Land: Clearview AI faces Court of Appeal test of GBP 7.5 million UK fine (October 2026)
- legislation.gov.uk: Sexual Offences Act 2003, section 66B (sharing or threatening to share intimate photograph or film)
- GOV.UK: Better protection for victims thanks to new law on sexually explicit deepfakes
- Ofcom: Statement, protecting people from illegal harms online
- Action Fraud: the UK's national reporting centre for fraud and cyber crime
Related pages
- Is face search legal?What biometric and privacy laws in the US, EU, UK, India, Canada and Australia mean for engines and for the people who use them.
- Face search law: European UnionGDPR Article 9, the household exemption, the AI Act's scraping ban, the PimEyes and Clearview AI cases, and the rights you can enforce.
- Face search law: United StatesBIPA, CUBI, Washington, California, FCRA and the Take It Down Act, and what each means for engines and for searchers.
- Intimate image abuseHelp lines and hashing tools first, then how to find public copies to report and what a face search cannot do.
- Fake account using your photosLock down the evidence, find every copy with a face search, and report the impersonator on each platform.
- Remove my photosHide your face from FaceSearch results for free, by email, with a confirmation when it is done.
Your face is out there. Find it first.
Search with a photoPublic pages only. Your photo is never sold and never used to build a face database.