GDPR Data processing modelWorkplace access control with person over template control
Purposes (2)
A purpose is the objective pursued by the setting up of your file. It indicates what the processing of personal data will be used for, its purpose. This purpose must be clear and understandable
Data categories (3)
Personal data is any information relating to an identified or identifiable natural person. A natural person can be identified either directly (eg surname and first name) or indirectly (eg phone number, social security number, email or postal address, but also voice or image)
Data on employees' working lives
Data details
Data conservation rules
Active base:
Duration of employment contract
Destruction
Employee movement logs
Data details
Data conservation rules
Active base:
Active: 3 months maximum (proportionality and necessity test).
Information Commission (ICO) monitoring workers guidance
Destruction
Employee identification data
Data details
Definition
- Type 1 : templates under the control of the persons concerned are those whose only durable storage medium is held by the person him/herself, e.g. in the form of a badge or smart card ;- Type 2 : Templates under shared control are those whose durable storage medium is controlled by the employer or his employees, but which are kept in a form that makes them unusable without the use of a secret held by the person concerned;Type 3: templates not controlled by the persons concerned are those whose permanent storage medium is controlled by the employer or his agents in an exploitable form requiring neither a badge containing the template nor the use of a secret controlled by the person concerned.
Definition
Photograph including the person's face
Data conservation rules
Active base:
No statutory period applies; the controller should set the periods based on the purpose (UK GDPR, Article 5(1)(e)). Biometric data are special category data and a non-biometric alternative (badge, PIN) should be offered. For example: the biometric template is kept only while the person's access authorisation is valid and is deleted when the person leaves or opts for the alternative; identity, professional and parking data are deleted 3 months after the end of a one-off access authorisation and, for long-term access, after a period set by the controller (for example 12 months after departure, or up to 6 years where needed to defend contractual claims under the Limitation Act 1980, s.5).
UK GDPR, Article 5(1)(e); Limitation Act 1980, s.5
Destruction
Data subject (1)
A data subject is any person whose data is collected, retained or processed by the data processing. e.g. In a recruitement process, any candidate for a position proposed in recruitement management process
- Employees
Attribution / Pas d'utilisation commerciale
CC-BY-NC
