Important in relation to using biometrics for time and attendance05/07/2019
Important to offer the employees an alternative to the biometric solution
On 29 May 2019, the Danish Data Protection Agency published an indicative opinion on the use of fingerprints (biometrics) for the purpose of registering employees' time and attendance as part of the control of the employees' working hours.
Since this is an interpretation of the EU GDPR, it is likely to be interpreted in the same way in other EU and affiliated countries, and in that case we give this recommendation.
In the guide, the Data Protection Agency states that an employee cannot validly give consent to the treatment of fingerprints if it is the only solution offered.
It is therefore important to offer the employees an alternative to the biometric solution, e.g. a card or a code.