Judgment Approved by the court for handing down. R (Bridges) -v- CC South Wales & ors in the present arrangements is that that data is deleted in the vast majority of cases. That does not mean, however, that the software may not have an inbuilt bias, which needs to be tested. In any event, with respect to Mr Edgell, he is not an expert who can deal with the technical aspects of the software in this context. 192. We should address another submission which was made to us by Mr Beer for SWP although it did not feature in the reasoning of the Divisional Court. This submission arises from the scientific evidence which has been filed in these proceedings. 193. When the claim for judicial review was first lodged, reliance was placed in the Statement of Facts and Grounds on the first witness statement of Dr Anil Jain, dated 30 September 2018. Dr Jain is a professor in the Department of Computer Science and Engineering at Michigan State University in the United States. In his first witness statement he explains that the performance of AFR technology is affected by a number of variables, including “training datasets”: see para. 38(a). What this means is that the particular software which is used is “trained”. At para. 47, Dr Jain says that the accuracy of an AFR system depends to a considerable extent on the training dataset. He goes on to say, at para. 48, that AFR systems can suffer from training “bias”. At para. 49, he says that one cause of such training bias can be any imbalance in the demographic of subjects in the training datasets, resulting in the AFR system having a high false alarm rate or a high false reject rate for that particular demographic. At para. 51 Dr Jain states that it would appear that SWP were not aware of the dataset used to train the AFR system in this case. For that reason, he states, it would be difficult for SWP to confirm whether the technology is in fact biased. As a minimum for confirming whether an AFR system is biased, the database statistics, such as the number of males to females, and different races considered, would need to be known. 194. At the hearing before us Mr Beer placed particular reliance on a witness statement, filed in response to the first witness statement of Dr Jain, by Mr Paul Roberts, dated 23 November 2018. The first point to note about Mr Roberts’ statement is that it was obtained in response to the challenge brought in the present proceedings; it was not obtained proactively by SWP in order to fulfil the PSED. 195. Mr Roberts was employed by NEC (UK) Ltd as Head of Products and Solutions for Facial Recognition and is now employed by Northgate Public Services (UK) Ltd as Head of Global Facial Recognition. Both companies are subsidiaries of NEC Corporation. One of the products of the business is the NeoFace Watch software with which the present case is concerned. 196. Mr Roberts makes the point in his witness statement that Dr Jain’s report gave a generic description of generally available AFR software in the marketplace but is not a fully accurate description of NeoFace Watch. He states that the NeoFace algorithm is trained in laboratories and, on a typically annual basis, a new version of the algorithm is released containing improvements from, amongst other things, additional training. No further training is carried out by the system in any customer environments: see para. 10 of his witness statement. At para. 20, Mr Roberts states that the precise makeup, scale and sources of the training data used are commercially sensitive and cannot be released. He was, however, able to share certain facts, which he sets out in the following paragraphs. At para. 22 he states that: