Explicit consent
Offer a genuine alternative for people who say no.
Region · United Kingdom
Face verification in the United Kingdom.
Under UK GDPR, biometric data used to uniquely identify someone is special category data. You'll need a lawful basis, an Article 9 condition and usually a DPIA.
UK GDPR · DPA 2018Key laws
What applies in United Kingdom.
ART 9
UK GDPR special category
Biometric data processed to uniquely identify a person needs an Article 9 condition — typically explicit consent.
DPA
Data Protection Act 2018
Schedule 1 sets additional conditions and requires an appropriate policy document for some processing.
ICO
Biometric recognition guidance
The ICO's guidance explains when biometric recognition is special category data and what safeguards to apply.
SCA
Strong customer authentication
Under the UK's PSD2-derived rules, biometrics can be an inherence factor for payments.
Your checklist
What you need to do.
DPIA
Assess high-risk biometric processing before you start.
Processor contract
Put a UK GDPR Article 28 agreement in place — our DPA covers it.
International transfers
Use the UK IDTA or Addendum where data leaves the UK.
How SIMSIM helps
Privacy-first by design.
Templates, not photos
Less sensitive data held, smaller breach impact.
Deletion by API
Honour withdrawal and retention schedules in code.
Processor terms
A DPA with the transfer terms your market needs.
FAQ
Questions from teams in United Kingdom.
Is face verification special category data?
When used to uniquely identify or verify someone, yes. Detection alone usually isn't.
Do I need a DPIA?
In most biometric deployments, yes — the ICO lists biometrics among processing likely to be high risk.
Is there a UK version of your DPA?
Yes, our DPA includes UK GDPR terms and transfer mechanisms.
General information, not legal advice. Last reviewed 2026-09-30. Confirm requirements with qualified counsel.
Other regions
Operating in more than one market?
Building for United Kingdom?
Start free, or talk to us about DPAs, processing locations and volume pricing.