Best Privacy Practices When Using Biometric Matching For Authentication

Nok Nok Labs, an innovator in modern
authentication and a founding member of the FIDO (Fast IDentity Online)
Alliance, today published a White Paper from PwC Legal comparing key privacy
implications of on-device and on-server matching of biometric data.

For organisations considering biometrics as they move away from reliance on
usernames and passwords, the report highlights why device-side matching of
biometric data is a compelling approach to satisfy key privacy requirements
on cross-border personal data transfers, as well as providing the benefits of
individual choice and control around such personal data.

Biometric data is considered to be sensitive personal data and some
jurisdictions have already specifically referenced it in privacy guidance and
legislation. This paper emphasises key privacy considerations, sets out the
implications of processing biometric data in the EU, Switzerland, Canada, USA
and the Asia-Pacific region, and touches on best practice recommendations in
these jurisdictions.

“Biometric authentication and verification can be one of the most secure
ways to control access to restricted systems and information,” said Stewart
Room, partner at PwC Legal. “Unlike authentication based on traditional
passwords, authentication through biometric data is easier to use in
practice, and can be far more secure.

“However, this is a double-edged sword, because biometric data is extremely
sensitive due to its uniqueness and how intrinsic it is to a specific
individual. Additional efforts must be made to keep this data secure
including choosing a proper compliance system and infrastructure, training
staff how to handle it and protecting it from unauthorised access or

Other key findings in the White Paper include:

Freely given, informed user consent is required before processing biometric
data in almost every jurisdiction covered in the White Paper
With centralised storage of biometric data, the potential for large-scale
loss of data is significantly increased
On-device authentication will generally avoid international cross-border
biometric data transfer implications. Conversely, on-server authentication
for a global network of biometric users results in international transfers of
data; transfer of personal data, including biometric data, out of a
jurisdiction is generally restricted
“Biometrics are a compelling way to improve mobile application usability
and avoid the security pitfalls of username/passwords, but significant
privacy concerns come into play,” said Phillip Dunkelberger, President &
CEO of Nok Nok Labs. “With biometrics, it is crucial to understand the
difference between on-device and on-server matching, as the difference
between the two approaches significantly affects the risk and exposure of
data in a breach. The on-device approach, as used by Nok Nok Labs technology,
ensures optimal privacy for biometric information.”

The full report can be found here: