Official documentation
Recital 51 GDPR: Protecting sensitive personal data
gdpr-info.eu (Intersoft Consulting), 2016
Read the originalRead on October 16, 2026
- What it is
- Recital 51 of the GDPR explains why sensitive personal data deserves specific protection and says when photographs count as biometric data.
- How much weight it carries
- Recitals guide interpretation of the articles but are not themselves binding rules. Text reproduced on a reference site.
Facts taken from this source
- 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.
“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)