Policy controls that govern agency activity generally contain at least two components: (1) a substantive policy; and (2) a governance structure for ensuring implementation of and compliance with that policy. Effective controls require both. This proposal focuses on the second component, the governance structure. Specifically, it addresses routine monitoring, annual audits, enforcement of the AG’s policies that govern the facial recognition system, and public transparency. Established facial recognition policies, including those that the Task Force has looked to as models, recognize the importance of establishing such a governance structure.
We have reviewed existing federal and state policy templates documents in order to identify and integrate best practices. Based on this review, we believe that Ohio’s Facial Recognition Policy should address routine monitoring, periodic audits, enforcement, and public transparency. A policy that successfully integrated each of these elements would reflect best practices and could serve as a model for other states and localities.
Ray, Brian E. and Hirsch, Dennis, "Appendix B: Ohio Attorney General Facial Recognition Task Force Proposal on Monitoring, Auditing, Enforcement and Transparency" (2020). Law Faculty Reports and Comments. 10.