Judgment Approved by the court for handing down. R (Bridges) -v- CC South Wales & ors others should not be introduced without regular assessment to ensure the underlying data is fit for purpose.” “4.12.2 A system operator should have a clear policy to determine the inclusion of a vehicle registration number or a known individual's details on a reference database associated with such technology. A system operator should ensure that reference data is not retained for longer than necessary to fulfil the purpose for which it was originally added to a database.” Surveillance Camera Commissioner's AFR Guidance 33. The Surveillance Camera Commissioner has published “guidance” or “advice” on the use of AFR by the police in conjunction with CCTV entitled “The Police Use of Automated Facial Recognition Technology with Surveillance Camera Systems” (“the AFR Guidance”). The guidance explains the roles of the Surveillance Camera Commissioner and Information Commissioner in relation to the regulation of the police use of AFR. The Surveillance Camera Commissioner AFR Guidance is designed to assist relevant authorities in complying with their statutory obligations “arising under section 31(1)” of the PFA 2012 and the SC Code (paragraph 1.3). 34. The AFR Guidance was promulgated on the basis that the Surveillance Camera Commissioner “should provide advice and information to the public and system operators about the effective, appropriate, proportionate and transparent use of surveillance camera systems” (SC Code, paragraph 5.6). It is said that the AFR Guidance indicates “the way in which the Commissioner is minded to construe the particular statutory provisions arising from PFA 2012 and those provisions within the Code of Practice in the absence of case law” (paragraph 1.8). 35. The AFR Guidance focuses on the assessment of the necessity and proportionality of deployments of AFR. It also provides advice on conducting risk assessments and making use of the Surveillance Camera Commissioner's ‘Self-Assessment Tool’. In respect of watchlists there are suggestions concerning the nature of images used to produce watchlists. 36. Unlike the SC Code, there is no requirement for SWP to have regard to the AFR Guidance. This guidance was first published in October 2018 and re-published without changes in March 2019 (i.e. after the two deployments of AFR about which the Appellant complains). SWP Documents SWP Policy Document 37. SWP have issued a policy document entitled “Policy on Sensitive Processing of Law Enforcement Purposes, under Part 3 Data Protection Act 2018” (Version 2.0, November 2018) (“the November 2018 Policy Document”). That Policy Document sets out SWP's policy as regards compliance with the six Data Protection Principles in Part 3 of the DPA 2018: “3. Compliance with Data Protection Principles