For the specific research, the developers decide not to rely on a commercial database, nor to use computer-generated images. The developers decide to collectall the data (palmprints) that are necessary to achieve the goals of their research directly fromnatural persons.The developers will collect impressions of the palmprints and extract the distinctive physical features (e.g., measurements of the hand) from these impressions.
Tounderstand if biometric data are involved, developers adopt the criteria of article 4.14 GDPR.
| Biometric data checklist | ||
| ✓ | Amount to personal data | Yes, since the palmprints relate to an ’identified natural person’ |
| ✓ | Are based on specific technical processing | Yes, since the distinctive features will be extracted from palmprint’s impressions using technical processing |
| ✓ | Pertain to physical, physiological or behavioral characteristics | Yes, since palmprints relate to physical characteristics |
| ✓ | They allow or confirm unique identification of natural person | Yes, since the goal of the project is to use palmprints to identify natural persons |
| Legal regime: special categories of personal data | |||
| Does the activity involve biometric data | Yes | ✓ | Specific regime on special categories of personal data applies |
| No | Specific regime on special categories of personal data does not apply | ||