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) 4.4: 4.4 Biometric systems: accuracy checks, bias mitigation, manual review of access denials without detriment

The employer is responsible for the accuracy of biometric data even with a vendor system; it should think carefully about accuracy and suitability for the people captured, must consider whether the biometric type fits the use, should monitor performance and complaints, and must assess and mitigate bias, since facial recognition can be less precise for some demographic groups. Where access depends on solely automated identification, it must provide manual review of denials and let workers ask for review, should restore access quickly (an intercom to a supervisor, for example) and should not disadvantage those who ask for manual review.

Maintained by Gerard Blokdyk

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  • Art.22C Article 22C Safeguards for automated decision-making

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