The ICO has issued “phase 1” draft guidance on biometric data for public consultation.
The guidance covers:
- what biometric data is;
- when it is considered special category data;
- its use in biometric recognition systems; and
- the data protection requirements you need to comply with.
The guidance covers some basic definitions and concepts but also more interesting areas, particularly in relation to biometric recognition (i.e. using biometric data to uniquely identify someone) as well as consideration of potential lawful bases, the interaction with automated processing, the risks presented by the processing and how these might be dealt with.
The consultation will close on 20 October 2023. The draft guidance can be found here.