Regardless of the above, it is recommended to introduce personal data processing policy describing the rules of processing personal data in a unit. Reports from the analyses should be stored together with personal data processing documentation. Depending on the results, it may be necessary to conduct an assessment of the consequences processing may have for the rights and freedoms of the data subjects. For this purpose, a necessary step is to prepare a register of the processing operations and conduct the initial analysis of risks associated with personal data processing. WHAT EASY STEPS CAN BE TAKEN TO COMPLY WITH THE GDPR WHEN TAKING ID PHOTOS?Ī photograph shop that processed biometric data should ensure legal compliance of their processing process in the first place. GDPR imposes stricter responsibilities on such GDPR administrators than on administrators of “ordinary” data As a result, a photographer who only takes photographs that can be later used for biometric purposes does not process biometric data - as he or she does not use these photographs for identification by means of special technical means.Ĩ. Therefore, if a person uses a photograph for the purposes of biometric identification - he or she processes biometric data. This means that biometric data processing takes place only if we use images with special software designed for biometric identification.Īrticle 4(14): ‘biometric data’ means personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images or dactyloscopic data This results from the fact, that according to the GDPR, use of photographs is processing of biometric data only if they are processed by means of special technical methods that allow unambiguous identification of a natural person or confirmation of that person’s identity. However, the way it is processed (used) may be biometric data processing. According to the GDPR, a photograph itself is not a biometric data.
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