Contact
The consent of the affected personnel cannot be considered an adequate legal basis for the implementation of a time control system through facial recognition such as the one described in the consultation. It would be necessary to foresee this control system in a legal provision or in an applicable collective agreement, or where appropriate, in a pact or agreement resulting from collective bargaining, circumstances that do not seem to occur in the case analyzed.In any case, before the implementation of such a system, it is necessary to make an assessment of the impact on data protection in light of the specific circumstances in which the treatment is carried out to determine its legality and proportionality, including the analysis of the existence of less intrusive alternatives, and establish the appropriate guarantees.