Biometric access control privacy

 

Information on the processing of personal data carried out by Aeroporti di Roma S.p.A. for the testing of a facial recognition system at Fiumicino airport to facilitate access control of airport and boarding areas

 

In compliance with Article 13 of Regulation (EU) 2016/679 - General Data Protection Regulation (GDPR), Aeroporti di Roma S.p.A. ("ADR"), as the Data Controller, intends to provide those passengers interested in participating in the trial with certain information regarding the processing of personal data carried out by ADR as part of the testing of a pilot project relating to the installation of a computer system based on facial recognition technology (hereinafter, the "System") at Fiumicino airport, which is aimed at allowing departing passengers easier, faster and safer transit in the airport area, speeding up checks at gates at so-called security restricted areas and at boarding points, and reducing the relevant waiting times.

For the above purposes, passengers intending to take part in the trial are asked to provide, through the devices located at the kiosks and check-in desks dedicated to this purpose, some of their personal data, without which participation would not be possible.

In particular, in the initial phase, the System acquires, through specialised electronic readers: (i) some data contained in the passport: number, first name, last name, date of birth, date of issue and expiry, as well as the digital photo of the person concerned, which is stored only temporarily in order to process a biometric template relating to the facial characteristics, to be compared with the face that is detected and processed in real time by the camera on the devices (after verification, this template will be deleted); (ii) some data contained in the boarding pass (flight number and date, departure and destination airports and seat number), which are required for the usual airport checks. The System then acquires, through a camera, (iii) an image of the passenger's face, detecting their salient features, measuring them and transforming them into a numerical code (the so-called biometric template), which in any case does not allow for the originally-acquired image (which is immediately deleted from the device) to be traced, and which, following a positive comparison with what is obtained from the passport’s digital photo, is stored in encrypted form and transmitted, along with the data referred to in the previous letters (i) and (ii), to an electronic archive in a central server belonging to ADR, protected with high security measures.

This data will be kept in encrypted form and will be used to verify the passenger’s identity in the subsequent steps to the gates that are dedicated to the trial and equipped with the same facial recognition technology (highlighted with a specific infographic), placed before the security checks and boarding gates, so as to be able to extract and verify, in an automated way, the data relating to the identification document and boarding pass that allow access to these gates.

It should be noted that participation in the trial of the System described above is entirely optional for departing passengers, who remain free to use the usual methods of accessing the airport gates by scanning the boarding pass in their possession, subject, where required (e.g. at the boarding gates), to verification of the relevant identification document.

The processing of the passenger's biometric data (relating to facial features that are required for facial recognition) may be carried out by ADR only if the passenger intending to take part in the trial has given their consent, while the processing of the other personal data indicated above is necessary to execute the request for the same passenger to take part in the trial of the System and to provide the related services, to comply with the related regulatory and administrative obligations and to pursue legitimate interests related to the performance by ADR of organisational and technical activities relating to the operation and security of the System, the verification of the relative reliability and the analysis and evaluation of the results of the trial.

For the purposes outlined above, personal data is processed using electronic means and primarily automated procedures and may be disclosed to ADR's authorised personnel and service providers regarding the technologies, hardware and software used by ADR for the purposes of carrying out the trial and the technical activities of installing, managing and maintaining the System. These suppliers act on behalf of ADR as data controllers. The above data will not be disclosed to third parties, except for any requests for information by judicial authorities and judicial police required by law, and will not be the subject of any transfer to entities established in non-EU countries 

For the above purposes, personal data acquired and used for the operation of the System, including biometric data, will be stored up to one hour after the departure of the passenger's flight, after which it will be deleted.

The GDPR (Articles 15-22) guarantees the passenger, as a data subject, the right to request access to personal data concerning him or her; portability of the data provided if it is subject to automated processing based on consent or contract; rectification and/or integration if inaccurate or incomplete; erasure of personal data or restriction of processing if the conditions are met; opposition to processing on grounds related to their particular situation, and the right to revoke their consent at any time, without prejudice to the lawfulness of the processing carried out before revocation. This is also without prejudice to the right to lodge a complaint with the Italian Data Protection Authority where deemed necessary for the protection of their rights in this regard.

For further information regarding the aforementioned activity of processing personal data, and for exercising the aforementioned rights, the passenger may contact Aeroporti Di Roma S.p.A., as the Data Controller, with registered office in Via Pier Paolo Racchetti 1, 00054 Fiumicino (RM), and/or contact the relevant Data Protection Officer by sending an email to dpo@adr.it.

 

Updated on 19/11/2019