Employment
Biometric attendance: is convenience enough?
Executive summary
The Turkish authority’s clarification of principle decision 2026/921 states that valid consent does not resolve proportionality concerns where biometrics are processed solely for attendance. Converting a fingerprint to a mathematical code does not remove its biometric character.
Inventory each device by its actual function, data and purpose. A transition plan should cover old templates, backups and supplier copies as well as the replacement system. Different security purposes require their own assessment.
Sources
KVKK · 2026/921 sayılı ilke kararına ilişkin açıklama
This publication provides general information and does not replace legal advice on a specific matter.
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