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Scenario: A financial institution collectsbiometric data of its clients, such asface recognition, to support apayment authentication processthat they recently developed. The institution ensures thatdata subjects provide explicit consentfor the processing of theirbiometric datafor this specific purpose. Question: Based on this scenario, should theDPO advise the organization to conduct a DPIA (Data Protection Impact Assessment)?
Correct Answer: A
UnderArticle 35(3)(b) of GDPR, aDPIA is mandatoryfor processing that involveslarge-scale processing of special category data, including biometric data. Even ifexplicit consentis obtained,the risks associated with biometric processing require further evaluation. * Option A is correctbecausebiometric data processing poses high risks to fundamental rights and freedoms, necessitating a DPIA. * Option B is incorrectbecauseobtaining consent does not eliminate the requirement to conduct a DPIA. * Option C is incorrectbecauseDPIAs are required for biometric processing regardless of scaleif risks are present. * Option D is incorrectbecausestorage duration is not a determining factor for DPIA requirements. References: * GDPR Article 35(3)(b)(DPIA requirement for special category data) * Recital 91(Processing biometric data requires special safeguards)