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Article 35(3)(b) of the GDPR lists processing on a large scale of special categories of data, which include biometric data used to identify a person, as a case that requires a data protection impact assessment.

Checked against its source on October 17, 2026

In the source's own words

“processing on a large scale of special categories of data referred to in Article 9 (1)”

Art. 35 GDPR: Data protection impact assessment, gdpr-info.eu (text of Regulation (EU) 2016/679), 2016, Article 35(3)(b).

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What it measures
A data protection impact assessment is a documented check of the risks a processing activity poses to people, done before the processing starts. Article 9(1) defines special categories, which include biometric data used for unique identification.
What it does not show
The article lists the cases that always require an assessment and leaves the rest to the controller and the supervisory authority. Whether a given dictation or meeting tool processes data on a large scale is a question of fact for the controller.

Source

Cited on

GDPR requires an impact assessment for large-scale special category data | Yap