Netherlands GDPR Implementation Act (UAVG - Uitvoeringswet AVG, 2018)
Special categories of personal data (arts 22 to 30b) – Netherlands GDPR Implementation Act (UAVG - Uitvoeringswet AVG, 2018)

Netherlands GDPR Implementation Act (UAVG - Uitvoeringswet AVG, 2018) 29: Art. 29 Use biometric identification (fingerprint or face) only where necessary for authentication or security for a weighty public-interest access need

Under GDPR art. 9(2)(g), biometric data for uniquely identifying a person may be processed only where necessary for authentication or for security purposes, and (since the Verzamelwet gegevensbescherming, in force 1 September 2026) only insofar as necessary because of a weighty public interest in lawful access to particular places, buildings, services, products, information systems or work process systems. Convenience, cost saving and time registration are not such an access need (the AP has fined an employer for fingerprint-based time registration); outside this exception, explicit consent under art. 22(2)(a), rarely freely given by employees, is the only route. The Autoriteit Persoonsgegevens' DPIA list (Staatscourant 2019, 64418) requires a DPIA for large-scale or systematic biometric processing.

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

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