Trust

Does encrypting the fingerprint get around the ban?

No; converting biometric data into a mathematical code does not remove its status as special category personal data.

Detail

Template, digest or vector — whatever it is called, it remains tied to the person and is therefore subject to the same protection.

Encryption is therefore a security measure, not a legal basis.

Source

Source: Personal Data Protection Board principle decision, 29.04.2026, 2026/921.

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