Biometric Data Consent Form

[sarahstacey]

Happy Friday!

 

Could someone help me out with this please?

 

Does a biometric consent form need to be physically signed?

 

Or can it be an online google form?

 

I can't find an answer.

 

Many thanks

[Ditto]

Happy Friday!

 

Could someone help me out with this please?

 

Does a biometric consent form need to be physically signed?

 

Or can it be an online google form?

 

I can't find an answer.

 

Many thanks

I believe either is fine, but you'd be better placed if you can show evidence that the permission was given by the appropriate person. So signature is OK if paper based. If it is the pupil giving permission from a school google account and requires you to be signed in, that would be OK. If it's a Google Form but doesn't require you to be logged in, but perhaps the form filler provides an email address or DOB as id verification, it's not as good.

 

There is a argument that requiring permission is not required if you give notice of use of data. BUT, as this is Special Category Data that would take some defending and it's not a view shared by DfE. Have a look at the non-statutory advice here. Whether 'written' excludes 'electronically written' I don't know, but I think if you follow the advise in this document, you will have shown due care from a DPA/GDPR perspective.

 

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/692116/Protection_of_Biometric_Information.pdf

[GrumbleDook]

I believe either is fine, but you'd be better placed if you can show evidence that the permission was given by the appropriate person. So signature is OK if paper based. If it is the pupil giving permission from a school google account and requires you to be signed in, that would be OK. If it's a Google Form but doesn't require you to be logged in, but perhaps the form filler provides an email address or DOB as id verification, it's not as good.

 

There is a argument that requiring permission is not required if you give notice of use of data. BUT, as this is Special Category Data that would take some defending and it's not a view shared by DfE. Have a look at the non-statutory advice here. Whether 'written' excludes 'electronically written' I don't know, but I think if you follow the advise in this document, you will have shown due care from a DPA/GDPR perspective.

 

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/692116/Protection_of_Biometric_Information.pdf

 

Biometrics always requires permission for children as it is also subject to the Protection of Freedoms Act 2012, as mentioned in the above guide from DfE.