Summary

The board banned the processing of biometric data for access and working-time tracking. What the decision says, why explicit consent does not rescue it, and the order a school with a fingerprint turnstile should follow.

What the decision says

With principle decision 2026/921 dated 29 April 2026, the Turkish data protection board banned the processing of biometric data for access and working-time tracking. The ban does not depend on the method: fingerprint, vein pattern, palm geometry and face recognition all fall inside it.

The decision is not advice; processing that falls inside its scope is unlawful. The institution itself answers for it, because the school is the data controller — not the company that installed the turnstile.

Why explicit consent does not help

Explicit consent cannot make a prohibited processing activity lawful. On top of that, consent between a school and its students or parents is not freely given: when passing the gate is compulsory, the price of saying “no” is being unable to enter the school.

Encryption and hashing are not a defence either. A hash maps the same finger to the same value every time; it is a record that recognises a person, and it does not stop being biometric data.

What a school with a fingerprint turnstile should do

  • Move identification to a card, a tag or an identifier the institution issues itself; the turnstile, the panel and the reader can stay where they are.
  • Destroy the biometric templates and record the destruction; deactivating a record is not destroying it.
  • Update your privacy notice and any consent records you hold.
  • Set the retention and destruction period for access records yourself, as the institution.

The signal at the gate is enough without biometrics

A turnstile that reads a card or a tag answers two questions: who passed and when. The live presence list, occupancy, the pre-filled attendance draft, parent notifications and the emergency roster are all built from those two facts; none of them needs a fingerprint.

TurniGate does not process biometric data in any version, and does not offer it as a setting either.

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