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) 4.7: 4.7 Biometric security: risk-appropriate measures; templates kept only as needed, refreshed, non-reversible and stored apart

The employer must have security appropriate to the risk of unauthorised access to biometric data, which cannot usually be changed after a breach, should consider whether it needs the underlying image or only the template, and should apply technical (encryption) and organisational (access restriction) measures. For templates it must not hold them longer than necessary, must keep them accurate and refreshed as needed, must store them so they cannot be reverse-engineered into the image or identity (encrypted), and must not store them alongside associated images or lists.

Maintained by Gerard Blokdyk

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  • Art.32 Article 32 Security of processing

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