Judgment Approved by the court for handing down. R (Bridges) -v- CC South Wales & ors freedom of assembly under Article 11 of the Convention and freedom of expression under Article 10 of the Convention. There is no further elaboration of those points. The skeleton argument concludes, on this ground of appeal, that in the light of those three alleged deficiencies, the DPIA fell foul of the test specified by the Divisional Court itself (at [146]), namely: “If it is apparent that a data controller has approached its task on a footing that is demonstrably false, or in a manner that is clearly lacking, then the conclusion should be that there has been a failure to meet the section 64 obligation”. 148. Mr Facenna’s skeleton argument made the following criticisms of the DPIA. First, the DPIA contained no assessment of the impact of the deployment of AFR on the protection of the personal data of members of the public who might be affected by the measures. Secondly, it contained no assessment of the risks to their rights and freedoms, so that, for example, there was little or no engagement with the fact that SWP’s use of AFR involved the collection of data on a blanket and indiscriminate basis, and it placed too little weight on the interference posed by the initial collection itself and the plainly ambitious scale of the collection, particularly bearing in mind that it involved the sensitive processing of biometric data. Thirdly, the assessment did not adequately address the risk that a false positive would result in innocent members of the public having their biometric data retained for longer periods and place them at risk of being subjected to more intrusive interventions by police. Fourthly, the assessment of the right to privacy under Article 8 of the Convention, privacy risks, and possible mitigation of those risks, was negligible at best, being more concerned with the technical operation of AFR. 149. In his oral submissions Mr Facenna said that the DPIA did not contain an assessment of privacy, personal data and safeguards. He said it contained no acknowledgment that AFR involves the collection of data on a blanket and indiscriminate basis and that the risk of false positives would mean a longer period of retention. He criticised the DPIA for failing to address the potential for gender and racial bias. Generally, he submitted that there was a failure in the DPIA to provide an assessment of the risks and mitigation of them, as required by section 64 of the DPA 2018. He said that the Divisional Court’s dismissal of the claim under section 64 has to be seen in the context of the conclusion of the Divisional Court that Article 8 was not infringed for non-matched members of the public. 150. Some of the criticisms now advanced by the Appellant and the Information Commissioner in respect of the DPIA fall outside the alleged two material errors of law specified in this ground of appeal. They include the point in Mr Squires’s skeleton argument that the DPIA does not refer to interference with the Convention rights to freedom of assembly and expression (Articles 10 and 11) and Mr Facenna’s arguments that a false positive would result in innocent members of the public having their biometric data retained for longer periods and place them at risk of being subjected to more intrusive interventions by police and that the DPIA failed to address the potential for gender and racial bias. 151. We agree with the Divisional Court that some of the criticisms of the DPIA made by Mr Squires and Mr Facenna are unjustified. The DPIA specifically acknowledged that