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Since blockchain transactions are classified as pseudonymous, are they considered to be within the material scope of the GDPR or outside of it?
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Question 132 - CIPP-E discussion

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Many businesses print their employees' photographs on building passes, so that employees can be identified by security staff. This is notwithstanding the fact that facial images potentially qualify as biometric data under the GDPR. Why would such practice be permitted?

A.

Because use of biometric data to confirm the unique identification of data subjects benefits from an exemption.

Answers
A.

Because use of biometric data to confirm the unique identification of data subjects benefits from an exemption.

B.

Because photographs qualify as biometric data only when they undergo a "specific technical processing''.

Answers
B.

Because photographs qualify as biometric data only when they undergo a "specific technical processing''.

C.

Because employees are deemed to have given their explicit consent when they agree to be photographed by their employer.

Answers
C.

Because employees are deemed to have given their explicit consent when they agree to be photographed by their employer.

D.

Because photographic ID is a physical security measure which is "necessary for reasons of substantial public interest''.

Answers
D.

Because photographic ID is a physical security measure which is "necessary for reasons of substantial public interest''.

Suggested answer: B

Explanation:

According to Recital 51 of the GDPR, photographs are not automatically considered as biometric data, unless they are processed by a specific technical means that allows the unique identification or authentication of a natural person1. This means that printing employees' photographs on building passes does not necessarily involve biometric data, as long as the photographs are not used for facial recognition or other similar purposes.The other options are incorrect, as they do not reflect the definition of biometric data or the conditions for processing special categories of personal data under the GDPR2.Reference:

Recital 51 of the GDPR

ICO guidance on special category data

Reference https://ess.csa.canon.com/rs/206-CLL-191/images/IAPP-Top-10-Operational-Impacts-of- GDPR.pdf?TC=DM&CN=CSA_OMNIA_Partners&CS=CSA&CR=T1_Gov%20GenNonProfit (11)

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asked 22/11/2024
AMMAR SHEIKH SALEH
33 questions
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