Biometric systems — fingerprint and face attendance, biometric access control — capture data that uniquely identifies a person and can't be changed if leaked. The DPDP Act applies, and biometrics deserve extra caution even though the Act has no separate 'sensitive' tier.
Is biometric collection necessary?
Ask first whether you need biometrics at all, or whether a card or PIN achieves the purpose. Data minimisation favours the least intrusive option that works.
Basis, notice and consent
Give a clear notice and, for employees, note that attendance can be an employment legitimate use — but offer an alternative where you can, and get consent for anything beyond strict attendance.
Security is critical
Store templates (not raw images) where possible, encrypt them, restrict access, and never reuse biometric data for new purposes. A biometric breach is irreversible.
A biometrics checklist
- Justify necessity; offer non-biometric alternatives.
- Notice and consent; purpose limitation.
- Encrypted templates, strict access, no reuse.
- Short retention; delete on exit.
How DPDP Bridge helps
DPDP Bridge helps you deploy biometrics lawfully — necessity, consent, encryption and tight purpose limits for this high-risk data. Take the free assessment to see exactly where you stand and what to do next.
This article is general information about the DPDP Act and is not legal advice. For guidance specific to your organisation, take the free assessment or speak to our team.