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The European Data Protection Supervisor (EDPS) has issued a report on a proposed EU Regulation on strengthening the security of identity cards that foresees several measures, one of which is to include two fingerprints in interoperable formats (article 3.3 proposed regulation) on national identity cards and similar identity documents.

The report, available in English at this link, notes the different functions of national identity cards and passports, highlighting the risks attached to this measure.

Although identity cards are often used in the framework of free movement within the European Union (known as the Schengen Area), the EDPS has concluded that EU citizens mainly use them in their interactions with private entities, not to exercise their right to free movement within the EU. Therefore, it considers that, as there are other valid and secure ways to identify citizens (e.g., passports), including fingerprints on national identity cards has not—at first sight—been sufficiently justified and requires a more thorough analysis.

Also, the EDPS considers that the data minimization principle must be safeguarded, which entails the need to ensure that, after the fingerprints have been scanned and added to the chip on the national identity cards, the Member States will not store any copies of that data. This measure would avoid situations that could potentially harm the data subjects, e.g., the creation by the Member States of parallel databases containing that biometric data.

In addition to the above measure, to safeguard EU citizens’ rights, the EDPS recommends not scanning the fingerprints of children under 14 and storing only a subset of the characteristics of fingerprints, not the entire fingerprint.

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