A grade school is planning to use facial recognition to track student attendance. Which of the following may provide a lawful basis for this processing?

Question

Options

• AThe school places a notice near each camera.
• BThe school gets explicit consent from the students.
• CProcessing is necessary for the legitimate interests pursed by the school.
• DA state law requires facial recognition to verify attendance.

• A
  8% (3)
• B
  59% (23)
• C
  13% (5)
• D
  21% (8)

Explanation

The use of facial recognition technology to track student attendance involves the processing of biometric data, which is a special category of personal data under the GDPR. Such data can only be processed under certain conditions, one of which is the explicit consent of the data subject. Therefore, the school may provide a lawful basis for this processing if it obtains the explicit consent of the students (or their legal guardians, if the students are minors). The consent must be freely given, specific, informed and unambiguous, and the students must have the right to withdraw their consent at any time.

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