Potential biometric special-category processing: What does this evidence support?
Cross-visit matching indicates identification, potentially making the embeddings biometric special-category data under GDPR context.
The question
In an EU retail demand-planning pilot subject to the GDPR, cameras count returning shoppers. The vendor says images are discarded, but its embeddings match shoppers across visits. What does this evidence support?
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- Potential biometric special-category processing for uniquely identifying people ✓Matching embeddings across visits indicates identification purpose; biometric data become special-category data when processed to uniquely identify persons.
- A lawful processing operation once the retail forecasting purpose is documentedDocumenting a legitimate business purpose does not itself establish a lawful basis or satisfy special-category conditions.
- Ordinary image processing without personal-data implicationsCross-visit matching can relate records to individuals, so discarding original images does not establish anonymous processing.
- A nonpersonal analytics system because the vendor calls embeddings irreversibleVendor terminology is insufficient; technical and contextual reidentification possibilities determine whether information remains personal data.
The trap
Focus on what the system does with the data, not merely the data format or supplier description. How to remember it
Cross-visit matching indicates identification, potentially making the embeddings biometric special-category data under GDPR context.
How many of these would you get right?
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