I'm not sure that the biometric data on these devices is precisely
personal information: an algorithm is stored which could not be used to
identify an individual (it is used to validate the fingerprint: it is
not a representation of the fingerprint). So personally I wouldn't worry
about it. What do others think?
Ben
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Donald Henderson
Sent: 27 May 2009 14:07
To: [log in to unmask]
Subject: Re: [data-protection] Biometric Data on Flash Drive
Phil,
Isn't the pragmatic answer to ensure that the device is wiped /
reformatted within an appropriate time period of a user leaving (say a
year) ? That would mean the biometric data is no longer held
indefinitely, but would still be "required" to be held operationally
(since it couldn't be removed) up to the point of re-formatting.
Periodic reformatting of all such devices might be considered a good
thing anyway to ensure that only those who need to use such a device can
do so.
Regards
Donald Henderson
Information Compliance Manager
Perth & Kinross Council
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Phil Bradshaw
Sent: 27 May 2009 12:02
To: [log in to unmask]
Subject: [data-protection] Biometric Data on Flash Drive
We currently issue and use secure USB flash drives which are accessed
using biometric (fingerprint) recognition.
http://www.beyondifsolutions.com/Stealth_MXP_Feb_23_06.pdf
These can register up to 6 users with their own encrypted secure area.
If we register more than one user, and one of these leaves (as we all do
eventually !) the profile can be removed by an administrator, but I am
advised that technically the biometrics remains on the device - no-one
including the user can actually gain access to the biometric profile, as
such it cannot be taken off the device or accessed by anyone else
including .
It can only be removed by an administrator wiping / reformatting the
device.
How do I reconcile this with the fifth principle - personal data not to
be kept longer than necessary ? Is it permissible to say since no-one
can access it we do not hold it / are no longer keeping it ?
Because of the high cost compared to 'open' USB drives it is
impractical to have one device per user where only occasional use is
required
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