Document the identification purpose and Article 9 basis | AIGP
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Document the identification purpose and Article 9 basis: Which evidence should resolve approval?

AIGP Understanding How Laws, Standards and Frameworks Apply to AI Hard

Resolve the actual unique-identification purpose, biometric processing facts, and applicable Article 9 exception.

The question

Under the GDPR, an energy company wants facial imagery from maintenance sites to identify authorized technicians. The vendor calls the service “image analytics,” but the identification purpose and applicable Article 9 condition are undocumented. Which evidence should resolve approval?

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  1. Limit cameras to daylight maintenance periods
    Operating hours may reduce collection, but they do not establish whether the processing uniquely identifies people or satisfy an Article 9 exception.
  2. Set retention limits and restrict access to site managers
    Retention and access controls are useful safeguards but do not resolve the biometric classification or special-category condition.
  3. Accept the supplier’s image-analytics classification after recording its rationale
    The supplier’s label does not determine GDPR classification; the organization must assess the actual purpose and processing context.
  4. Document the identification purpose and Article 9 basis ✓
    The company must establish the actual unique-identification purpose, whether biometric data are processed, and which Article 9 exception, if any, applies.
The trap
Classify biometric processing by actual purpose and context, then examine the applicable special-category exception.

How to remember it

Resolve the actual unique-identification purpose, biometric processing facts, and applicable Article 9 exception.

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Part of the Certsqill AIGP question bank · Understanding How Laws, Standards and Frameworks Apply to AI · Every answer, right and wrong, comes with its own explanation.