Q) Do I need to conduct a DPIA when considering using facial recognition cameras?
A) Every time facial recognition technology is used on a new site, the company must complete an updated DPIA and document its lawful basis for using the tech. It also needs to examine how this affects people whose data it captures
Q: Should documentation for using FRT available upon request?
A) The justification for using FRT and the decision-making behind the justifications are fully documented and available upon request
Q) What are the strict guidelines on the implementation of FRC ?
When a gym uses facial recognition for member access, and makes it the only option without any alternative, it is not considered valid consent under GDPR. Members are not given a real choice, as denying consent means they cannot access the gym. While facial recognition has some benefits, it is not necessary solely for gym access. Therefore, this arrangement does not comply with GDPR requirements.