SERIES: 30 PERSONAL DATA PROTECTION COMPLIANCE SCENARIOS IN EVERYDAY BUSINESS OPERATIONS - #2: TIMEKEEPING USING FINGERPRINTS OR FACIAL RECOGNITION: WHERE SHOULD BUSINESSES EXERCISE CAUTION?
- loanlelawlinkvn
- 6 days ago
- 2 min read
In many organizations, timekeeping through fingerprint or facial recognition is considered an effective solution to control working hours and enhance accuracy in HR management. However, from a compliance perspective, this is not merely a technology issue—it is also about the necessity and risk level of the data being processed.
Compared to conventional timekeeping methods, biometric data is inherently more sensitive in practice. Therefore, before implementation, businesses should ask several fundamental questions: Is biometric data truly necessary for this purpose? Are there less intrusive alternatives? And if implemented, how will access, retention, and data security be controlled?
A common mistake does not lie in the decision to adopt such technology, but in implementing it too quickly while internal processes, employee notices, and technical safeguards have not kept pace. This often results in a situation where the system is operational, but the associated data risks are not properly governed.
Recommendations for employers:
Before implementing or expanding biometric timekeeping systems, businesses should conduct a holistic review from HR, Legal/Compliance, and IT perspectives.
Mini-checklist:
Identify why biometric methods are necessary;
Assess whether less intrusive alternatives are available;
Review the types of data collected, storage locations, and security measures;
Restrict access to biometric data;
Review internal documentation and the information provided to employees regarding data processing practices.
In high-sensitivity data processing activities, operational convenience should not be the sole factor driving business decisions.
Legal reference: Law on Personal Data Protection No. 91/2025/QH15 and its implementing regulations, particularly provisions on data processing principles, sensitive personal data, data security, and the responsibilities of data-processing organizations.
CTA: Access and download the biometric timekeeping review checklist is available in the link below:
💌 Next Article: Using AI tools to process CVs, contracts or customer emails: Where is personal data going?
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Article: Prepared by LLVN.
Image: LLVN
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