Another thing to consider is Principle 4. If an employee grows or loses facial hair, piercings, tattoos, etc., is the data processed - the photograph - still accurate and up-to-date?
In a recent discussion I had on this topic, even the more common matter of changes of hair style and colour was raised, with illustrations of how a person's appearance could change radically.
The question was then posed as to what action - if any - the Data Controller should/must take in the instance that people say, of a Data Subject, "You look nothing like your photograph."
The view overall was that this area was no big issue, but discussion of these matters forms part of a proper risk/privacy assessment and should be documented, with decisions and the reasons for these.
M
Sent from my iPad
On 22 Jan 2013, at 05:09, Lynn Wyeth <[log in to unmask]> wrote:
> One consideration, photos can potentially show ethnicity/ religion (e.g. Asian wearing a turban) and therefore possibly be sensitive data needing consent.
>
> We looked at it here and I objected. It is now opitional. We had concerns about putting photos out in public domain if staff that may be in areas of work where they could then be at risk if recognised outside of work etc. Also concerns about photos being used fraudulently to impersonate officers.
>
> Just some things to consider.
>
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