Principle Decision On Processing Biometric Data For Timekeeping Purposes

The Personal Data Protection Board (“the Board”), through its Principle Decision dated 29 April 2026 and numbered 2026/921 (“the Principle Decision”), has determined that practices involving the processing of biometric data for employee timekeeping purposes are, as a general rule, unlawful data processing activities. The Principle Decision was issued in response to the increasingly widespread use by employers of biometric identification systems, — such as fingerprint, facial recognition, iris, or retina scanning — for employee attendance tracking, driven by technological developments.

The Board emphasized that, although labor law legislation imposes obligations regarding the monitoring and documentation of working hours, there is no explicit statutory provision requiring that such monitoring be carried out through the processing of biometric data. Accordingly, the Board concluded that biometric data processing conducted for timekeeping purposes cannot be grounded in the “explicitly