Workplace monitoring: biometric technology?

Earlier this year, the Information Commissioner’s Office (ICO) ordered Serco Leisure, Serco Jersey and seven associated community leisure trusts (Serco Leisure) to stop using facial recognition and fingerprint scanning technologies to monitor workers’ attendance.


Serco Leisure was using facial recognition and fingerprint scanning technologies to monitor the attendance of more than 2,000 employees at 38 leisure facilities.

Employees were not proactively offered an alternative to having their faces and fingers scanned to clock in and out of their workplace; it was presented as a requirement for being paid.


The ICO found that Serco Leisure failed to show why using facial recognition and fingerprint scanning technologies was necessary or proportionate when less intrusive means were available, such as ID cards or fobs.

It further found that, due to the imbalance of power between Serco Leisure and its employees, employees would likely feel unable to refuse the collection and use of their biometric data for these purposes.


The ICO issued enforcement notices, instructing Serco Leisure to stop processing biometric data for these purposes and destroy all biometric data that they are not legally obliged to retain within three months of the notice being issued.


Before introducing biometrics or other technologies to monitor staff, you should:

  • Consider why you want to use biometric technology and whether any alternative options are available.
  • Fully understand how the proposed biometric technology will work for its intended use.
  • Consider whether the biometric technology is appropriate for its intended use and whether any less intrusive method is suitable.
  • Determine whether there is a lawful basis for processing biometric data and what that is.
  • Be transparent about biometric technology, ensuring that data subjects are fully informed.
  • The ICO has published helpful guidance for employers on using biometric data in the workplace.
  • If Labour is elected to power, it plans to work with workers, trade unions, and employers to promote best practices for safeguarding against the invasion of privacy through surveillance technology, spyware, and discriminatory algorithmic decision-making.

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