Can we use fingerprint scanning of employees?
Fingerprints are a form of biometric information which is inherently sensitive. Employers will need to adhere to the Biometrics Processing Privacy Code if they want to use fingerprint scanning in their business.
We have detailed guidance about biometrics as well as factsheets that give a short description of each rule.
Organisations may only collect biometrics if it is necessary for a lawful purpose, appropriate privacy safeguards have been implemented, and the collection of biometrics is proportionate to the risk and impact on people.
The rule 1 guidance provides more about the collection rules for biometrics.
If organisations collect biometrics, they must be transparent, so people know about their use of biometrics.
Organisations must tell people, which includes their employees, the following information before or at the time their biometric information is collected:
- The fact that the biometric information is being collected.
- Each purpose for which the biometric information is being collected.
- Whether there is any alternative option to biometric processing that is available.
This information must be communicated in a clear and obvious way.
The rule 3 guidance provides more about the transparency rules and the limited exceptions to the notification requirements.
The employer must also inform the employees why the collection is necessary and what it will be used for before any fingerprint scanning system is installed or used. It’s also important for employers to explain how the information collected will be kept secure. Employers should also have clear processes for disposing of information(external link) once an employee leaves the organisation.
Organisations must also provide individuals with information about their rights to access(external link) and that they can request correction (external link)of the information.
Employers should do a Privacy Impact Assessment(external link) to make sure the risks have been addressed before implementing this technology.
Updated August 2025