Catherine Murphy (Kildare North, Social Democrats)
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566. To ask the Minister for Employment Affairs and Social Protection if her Department processes biometric data in the context of the definition of biometric data in article 4; and if she will make a statement on the matter. [31537/18]

Regina Doherty (Meath East, Fine Gael)
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Biometric data, as defined in the GDPR, Article 4. 14, means “personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images or dactyloscopic [fingerprint] data.”

The GDPR clarifies that the processing of certain personal data, such as photographs, should not systematically be considered as biometric data unless such personal data is processed through a specific technical means allowing the unique identification or authentication of a natural person.

The collection and printing of a simple JPEG image on the Public Service Card (PSC) does not therefore constitute the collection or processing of special category data.

I wish to be clear however that these photographs are, in addition to being printed on the PSC, processed, in a separate process, via facial imaging software to create an arithmetic template which is used to detect potential identity fraud. This arithmetic template is not stored on the Public Services Card, does not form part of the public service identity set, and is not shared with any other third party. They are stored only in the facial image matching software’s database held in the Department’s own secure data centres.

The Department is satisfied that its use of facial imaging software is compliant with the law and is covered by the current legislative framework including the GDPR, the Social Welfare Consolidation Act, and the Data Protection Act 2018.