Principle Decision on the Use of Biometric Data for Attendance Tracking

The Principal Decision of the Personal Data Protection Board dated 29 April 2026 and numbered 2026/921, published in the Official Gazette dated 2 June 2026 and numbered 33268, provides important guidance on the processing of biometric data for employee attendance tracking purposes.

In its Decision, the Board emphasizes that biometric data constitutes a special category of personal data and that its use for attendance tracking should be assessed in light of the principles of necessity and proportionality. The Board further notes that explicit consent may not always constitute a sufficient legal basis in the employment context and highlights the importance of considering less intrusive alternatives.

These developments are likely to have significant implications for employers utilizing fingerprint, facial recognition, or similar biometric systems in the workplace.

You may access our information note on the Decision here.