Processing is prohibited by default and requires: Because | AIGP
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Processing is prohibited by default and requires: Because this involves a special category of personal data,

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

Biometric data used to uniquely identify individuals is a special category, prohibited by default unless a specific exception such as explicit consent and safeguards apply.

The question

A company wants to add facial-recognition login that processes biometric data to uniquely identify employees. Because this involves a special category of personal data, what is the baseline lawful-processing expectation?

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  1. The biometric data may be processed on legitimate interests alone, provided the company documents the purpose in its processing records.
    Plausible because legitimate interests supports ordinary data, but special-category processing needs a specific Article 9 condition, not legitimate interests.
  2. A standard privacy notice is sufficient here, because biometric identifiers are treated much like ordinary contact and account details under the rules.
    Plausible as transparency matters, but a notice does not supply the lawful condition special-category data demands.
  3. Encryption of the stored biometric templates removes them from special-category status and any additional processing conditions.
    Plausible since encryption reduces risk, but it does not change the data's special-category classification or lift the conditions.
  4. Processing is prohibited by default and requires a specific legal exception, such as explicit consent, together with heightened safeguards. ✓
    Correct: biometric data used to uniquely identify a person is a special category, presumptively prohibited absent a specific exception and safeguards.
The trap
Treating biometric identifiers as ordinary personal data that legitimate interests or a privacy notice alone can justify.

How to remember it

Biometric data used to uniquely identify individuals is a special category, prohibited by default unless a specific exception such as explicit consent and safeguards apply.

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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.