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Typology of transparency as best practice: evidence from facial recognition technologies in Australia
Journal article   Open access   Peer reviewed

Typology of transparency as best practice: evidence from facial recognition technologies in Australia

Ausma Bernot, Rakibul Hasan, Milind Tiwari, Peita L. Richards and Brendan Walker-Munro
Information Communication & Society, Vol.First online, pp.1-19
08/07/2026
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Published (Version of record) Open CC BY V4.0

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Abstract

facial recognition technologies best practice transparency technology governance industry self-regulation public deliberation
Facial recognition technologies (FRTs) are commonly used inAustralia in an under-regulated environment. Only two regulatorymechanisms currently direct FRT use – industry self-regulationand Australia’s privacy laws. Currently, best practices for FRTdevelopment and adoption are a key governance mechanism,including the recent guide to FRT privacy risks evaluationpublished by the Office of the Australian InformationCommissioner in 2024. Transparency is lauded as one of the keyprinciples for implementation, yet it can be an elusive bestpractice to operationalize. Transparency spans everything fromtechnical design decisions and data governance to real-worldapplications, user communication, and regulatory compliance.Thus, our research critically considers the concept of transparencyin FRT governance by asking: What does transparency as bestpractice mean in the development and implementation of facialrecognition systems? This study sought to map multi-stakeholderviewpoints through problem-centered interviews (n = 30) withexpert technical, policy, and academic stakeholders making andinforming FRT policy in Australia. Based on their responses, wedevelop a typology of what transparency means in the context ofoperationalizing algorithmic surveillance technology governance,specifically FRTs. Our findings adopt a socio-technical perspectiveand identify five distinct modes of transparency in FRTs, includingtechnical, functional, procedural, public and contextual transparency.

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