Privintelligent conducted a privacy assessment of a digital tool (Application) adopted and used by the government in order to properly authenticate users. In the course of the assessment, our team:

• Determined the legal basis for the use of the tool and conducted thorough research on applicable law/ministerial decisions to assess the appropriateness of the said legal basis
• Mapped the lifecycle of the data processing activities, the applicable data categories as well as the sensitive data to be processed (biometric analysis of facial characteristics)
• Identified and assessed third parties and subcontractors participating in the project (infrastructure / IT / software providers), some of which acted as data processors
• Assessed the necessity and proportionality of the Application’s use with regards to the privacy rights of individuals and the provision of alternative admission options
• Proposed additional measures to cover transparency gaps in relation to the information provided to the general public in relation to the Application’s use (e.g., through the Application’s privacy policy)

Our recommendations aimed to ensure that the Application’s implementation is in compliance with the applicable regulatory provisions as well as best practices from a privacy perspective.