In the Guidance, the Board has pointed out that even though
biometric data is regulated as one of the special categories of
data per Article 6 of the Law No. 6698 on Protection of Personal
Data ("DPL"), the concept has
not been defined by domestic regulation as of yet. As such, the
Board made a reference to the Article 4 of the GDPR, wherein the
most comprehensive definition of "biometric data" reads
as follows:
Biometric data means personal data resulting from specific
technical processing relating to the physical, physiological or
behavioral characteristics of a natural person, which allow or
confirm the unique identification of that natural person, such as
facial images or dactyloscopic data.
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