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🔐 🇫🇷 No Biometrics for Monitoring Employees’ Working Hours! 🇫🇷 🔐

Biometrics & Video Surveillance | 25/03/2025

The CNIL has fined a company €10,000 for illegal use of biometric data.

Context

In 2017, a company was sanctioned for installing a biometric fingerprint recognition system to monitor its employees’ working hours without prior authorization from the CNIL.

👉 The CNIL emphasized that employers can only use biometric data technologies under exceptional circumstances, justified by specific security needs.

📌 Biometric data processing is prohibited when:

  • A badge system is sufficient.
  • It serves only for convenience.
  • The protected locations, applications, or devices are not particularly sensitive.

Violation of Article 9 of the GDPR: Sensitive Data

Processing biometric data for uniquely identifying individuals is prohibited, except under specific legal exceptions.

Case Details:

  • A company had implemented a fingerprint-based clock-in system for its employees.
  • After an inspection, the CNIL issued a formal request to:
    • Stop using the system.
    • Delete all collected biometric data within 3 months.
  • 8 months later, the CNIL found that:
    • The system was still in operation.
    • Biometric data collected over the past 7 years had not been deleted.

Consequences:

💰 Administrative fine: €10,000.
📢 Publication of the decision:

  • On the CNIL website.
  • On Légifrance, to raise awareness among data controllers about their legal obligations under GDPR.
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