Mick Wallace (Wexford, Independent) | Oireachtas source

Would the commission consider a company using facial image matching software to match a photograph of a person to other photographs or digital images stored in a database to be processing biometric data? Does this kind of facial image matching meet the definition of biometric data in Article 4(14) of the GDPR and the reference therein to "specific technical processing"? Last year, the Data Protection Commission issued guidelines in respect of biometric data. One type of biometric data it identified was raw images consisting of recognisable data such as an image of a face or a fingerprint. This appears to be in agreement with the Article 29 Working Party example of biometric data which specifically mentions a photograph of a face. It seems obvious to me that a photograph is a raw image consisting of recognisable data such as an image of a face. I ask the witnesses to confirm or clarify the position of the commission on the biometric nature of a photograph? Are photographs biometric data?