Is an image on CCTV recordings biometric data?
ANSWER
Merely recording an image on CCTV footage does not constitute processing of biometric data.
Biometric data are personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm the unique identification of that person (Article 4(14) GDPR).
Bearing the above in mind, for an image to be regarded as biometric data, it is not sufficient that the identity of a natural person can be established on its basis. In that case we are dealing with ordinary personal data. Qualifying an image as biometric data depends on the specific image processing technology adopted.
