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Scenario:A financial institution collectsbiometric data of its clients, such asface recognition, to support apayment authentication...

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Scenario:

A financial institution collectsbiometric data of its clients, such asface recognition, to support apayment authentication processthat they recently developed. The institution ensures thatdata subjects provide explicit consentfor the processing of theirbiometric datafor this specific purpose.

Question:

Based on this scenario, should theDPO advise the organization to conduct a DPIA (Data Protection Impact Assessment)?

A.

Yes, because biometric data is consideredspecial category personal data, and its processing is likely to involvehigh risk.

B.

No, becauseexplicit consenthas already been obtained from the data subjects.

C.

No, because DPIAs areonly requiredwhen processing personal dataon a large scale, which is not specified in this case.

D.

Yes, but only if the biometric data is storedfor more than five years.

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