Fact · Voice privacy and security
GDPR Recital 51 says photographs should not systematically be treated as special category data, because they count as biometric data only when processed through specific technical means that allow unique identification or authentication.
Checked against its source on October 16, 2026
In the source's own words
“The processing of photographs should not systematically be considered to be processing of special categories of personal data as they are covered by the definition of biometric data only when processed through a specific technical means allowing the unique identification or authentication of a natural person”
Recital 51 GDPR: Protecting sensitive personal data, gdpr-info.eu (Intersoft Consulting), 2016, Recital 51.
Open the original- What it measures
- The recital is about photographs. Regulators and lawyers apply the same reasoning to other raw captures, such as voice recordings, but the recital does not mention audio.
- What it does not show
- A recital guides interpretation and is not binding like an article. The extension to audio is an interpretation, not the recital's words.