A regional logistics company based in the United States is expanding fleet management operations into the European Union. The engineering team plans to deploy AI-driven in-cab cameras that continuously scan driver facial features to detect signs of fatigue and alert dispatchers. Because facial scanning involves processing special category biometric data to uniquely identify individuals, the security governance team must ensure compliance with EU data privacy regulations. Which of the following actions is mandatory prior to initiating this high-risk data processing activity?
- Conduct a Data Protection Impact Assessment (DPIA) to identify privacy risks and determine required safeguards.Answer
- BCommission a SOC 2 Type II audit report focusing specifically on physical security controls inside transport vehicles.
- CConfigure automated network firewalls on vehicle gateways to satisfy Sarbanes-Oxley Act (SOX) internal financial control mandates.
- DClassify the video telemetry streams as Protected Health Information (PHI) under the Health Insurance Portability and Accountability Act (HIPAA).
Answer
Conducting a Data Protection Impact Assessment (DPIA) is mandatory prior to processing high-risk biometric data under GDPR.
The General Data Protection Regulation (GDPR) classifies biometric data processed for uniquely identifying a natural person as special category data. Article 35 mandates that organizations conduct a Data Protection Impact Assessment (DPIA) prior to carrying out processing operations likely to result in a high risk to the rights and freedoms of individuals, such as automated systematic monitoring and biometric scanning.
Step-by-Step Solution
Key Concept
Data Protection Impact Assessment (DPIA) and GDPR Biometric Data Requirements