Ms Helen Dixon:

The SAFE 2 registration process involves taking a high-quality photo on site by the Department of Employment Affairs and Social Protection. The purpose of taking a high-quality photo is that an arithmetic template is generated by the Department, taking measurements from the face in the high-quality photo. These templates are then used to perform a photo-matching function on the system. The arithmetic template is biometric data per the definition in the GDPR. The question as to whether it is collecting biometric data-----