UK ICO Employment Practices and Data Protection: Monitoring Workers (2023)
Biometric data for time and access control and monitoring – UK ICO Employment Practices and Data Protection: Monitoring Workers (2023)

UK ICO Employment Practices and Data Protection: Monitoring Workers (2023) 4.2: 4.2 Biometric access: a lawful basis and a special category condition, and a non-biometric alternative without disadvantage

Using biometrics to identify workers is special category processing, so a lawful basis and a condition are both needed and must be documented in the DPIA. The employer should offer an alternative such as swipe cards or PINs to those who do not want biometric access and should not disadvantage them; without an alternative, biometric access control is very hard to justify and consent is not appropriate, whereas with a genuine, penalty-free alternative consent and explicit consent become likely options.

Maintained by Gerard Blokdyk

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  • Art.9 Article 9 Processing of special categories of personal data

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