fineConcludedSEK 200,000

Swedish Authority for Privacy Protection (IMY) Skelleftea Municipality Upper Secondary Board

August 20, 2019 · Sweden

In Europe's first GDPR facial-recognition fine, IMY fined the Skelleftea school board SEK 200,000 for a trial using facial recognition to register 22 students' attendance, finding it processed sensitive biometric data unlawfully and that consent was invalid given the students' dependent position.

Key takeaway — how to prevent this

Biometric data (faces, iris, fingerprints) needs an explicit lawful basis or consent. Scraping or capturing it without one is unlawful across the EU/UK and many US states (e.g. Illinois BIPA) — and draws the largest fines.

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