EDPB Guidelines 3/2019 on Processing of Personal Data through Video Devices
Section 5: Special categories of data and biometrics – EDPB Guidelines 3/2019 on Processing of Personal Data through Video Devices

EDPB Guidelines 3/2019 on Processing of Personal Data through Video Devices 5.1(b): 5.1(b) Biometrics: never capture people who have not consented; separate entrances and user-triggered capture

Where consent is the exception relied on, the system must not create templates of people who have not consented: biometric check points should be physically separated (a gantry or a dedicated entrance) from non-biometric ones, and capture should be triggered by the person, for instance by pressing a button. Systems in uncontrolled environments that scan everyone passing to find enrolled users need an Article 9(2) exception for every person captured, even if their templates are deleted at once.

Maintained by Gerard Blokdyk

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  • GDPR-Art.9 Processing of special categories of personal data

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Other controls in Section 5: Special categories of data and biometrics – EDPB Guidelines 3/2019 on Processing of Personal Data through Video Devices

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