Trust
Is switching the biometric system off enough?
No; if the data is still reachable, processing is considered to continue — deactivating is not destroying.
Detail
Turning the device off does not mean the templates on it were deleted; destruction must be carried out and recorded.
When moving to cards, destroying the old biometric records must be planned as a separate step.
Source
Source: Personal Data Protection Board principle decision, 29.04.2026, 2026/921.