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How to implement the biometric system?


A company decides to increase the security by introducing a biometric control for  the employees who have access to the buildings.


The management appointed a security service  to develop a biometric identification system.


The use of biometrics could present significant risks particularly linked with the possibilities of monitoring individuals and the interconnection of information and files.


The information systems management (ISD) offered two solutions to the general management: either a technology based on the storage template on a support which the data subject has exclusive use (smart card, cell phone, laptop, etc..) or to use a biometric element that leaves no trace, such as the contour of the hand. 


To avoid discrimination, it is necessary to provide alternatives for people who are not able to use a biometric system. The biometric identification data must be done only by comparing a sample taken from the data subject. The original biometric data must be destroyed once the enrolment procedure has been carried out.

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The objective must be clear, and  the most adequate and less intrusive means to achieve this must be chosen. These measures  must be the subjected to adequate communication. The employer should inform and consult the employees or their representatives and, if possible, obtain their consent before introducing the automated systems for the collection and processing of their personal data.

Basic principles

LIPAD 38  and 42 ; OLT3 26 ; CO 328 and 328b ; DPA 4, 12, 13 ; FoIA 6 

Privacy protection, workers protection, principles of legality, good faith and proportionality: the measures must be adequate, necessary and the least intrusive possible.


The private bank Pictet & Cie in Geneva have been using 3D facial recognition to secure the access to its buildings since 2006. How did they overcome the fears of its 2,000 employees? Through communication. This technology does not monitor the health of an individual and violate their privacy. "The employees feared that their facial scan could affect their health, which is not the case because the machine simply films," says Jean-Pierre Therre, in charge of the security of the private bank.  The database bank does not contain any photos of the employees either, but analyses the scans of their skulls according to the 40,000 reference points, and from which nothing can be drawn from. : http://www.1234economy.com/biometrie-et-reconnaissan ce-faciale-en-3d-comment-la-banque-privee-genevoise-pictet-a-gere-les-resistances /

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