Biometric access control privacy

Information on the processing of personal data in connection with participation in the trial run of a facial recognition system adopted by Aeroporti di Roma S.p.A. at Fiumicino airport to facilitate access control to airport and boarding areas

In compliance with art. 13 of (EU) Regulation 2016/679 - General Data Protection Regulation (GDPR), Aeroporti di Roma S.p.A. ("ADR"), as Data Controller, intends to provide passengers interested in participating with some information on the processing of personal data carried out by ADR as part of testing a pilot project relating to the installation at Fiumicino Airport of a computer system based on facial recognition technology (hereinafter, the "System"), aimed at allowing departing passengers an easier, faster and safer transit through the airport, speeding up the execution of controls at the gates of the so-called sterile areas and boarding areas, thereby reducing the related waiting times.

For the above-mentioned purposes, passengers wishing to participate in the trial are asked to provide, through the devices located at the kiosks and check-in desks set up for this purpose or through the application " ADR Innovation Biometrics" (hereinafter the "App") which can be installed free of charge on their mobile device (smartphone), some of their personal data, without which it would not be possible to participate.

In particular, in order to enable participation in the aforementioned project, the System acquires through special electronic readers (in the case of use of the APP through the camera and the device’s NFC sensor - smartphone - in use) (i) some of the data contained in the passport or electronic identity card: number, name, surname, date of birth, date of issue and expiry, as well as the digital photo of the person concerned, processed in order to develop a biometric template relating to facial characteristics, to be compared with that detected and developed in real time by the camera used at the dedicated sites at the airport or on the device in use (see. (ii) some of the data contained in the boarding pass (flight number and date, airport of departure and destination and seat number), necessary to allow the usual airport controls and, in the event of a positive outcome of an initial congruence check between the data contained in the identification document and in the boarding pass, it is then required to acquire, through the device's camera; (iii) an image of the passenger's face, capturing his/her facial features, measuring them and transforming them into a numerical code (so-called biometric template), which does not, however, allow the image originally captured to be traced and which, following a positive comparison with the image obtained from the digital photo taken from the identification document, is stored in encrypted form and transmitted, together with the data referred to in letters (i) and (ii) above, to an electronic archive on one of ADR’s servers, protected by high security measures.

This data will be stored in encrypted form and used to verify the identity of passengers at the airport when passing through the gates set up for the project and equipped with the same facial recognition technology (highlighted with a specific infographic), located before the security checkpoints and boarding gates, so as to be able to extract and verify the data relating to the identification document and boarding pass that enable access to these gates and/or the use of the services provided therein in an automated way.

Please note that participation in the trial run of the System described above and the release of the aforementioned personal and biometric data are completely optional for departing passengers, who remain free to use the usual methods of access to the airport gates, from reading the boarding card in their possession, without prejudice, where required (e.g. at the boarding gate), to the verification of their identification document.

ADR can only process the passenger's biometric data (relating to the facial features required for facial recognition) if the passenger who intends to take part in the trial has given his consent, while the processing of the other personal data indicated above is necessary to carry out the request of the same passenger to take part in the trial of the System and to provide the relative services, to comply with the related regulatory and administrative obligations and to pursue legitimate interests related to ADR's performance of organisational and technical activities relating to the operation and security of the System, verification of the relative reliability and analysis and evaluation of the trial results.

For the above purposes, the personal data are processed using electronic instruments and mainly automated procedures, and may be known by ADR's authorised members of staff and by the suppliers of services relating to the technologies and hardware and software equipment used by ADR for the purposes of carrying out the trial and the technical installation activities involved, as well as the management and maintenance of the System. These suppliers act on behalf of ADR as data processors. The aforesaid data will not be communicated to third parties, with the exception of any requests for information by the judicial authorities and the judicial police, which are required by law, and will not be transferred to subjects established in non-EU countries. 

For the above-mentioned purposes, the personal data acquired and used for the operation of the System, including biometric data, will be retained by ADR until a maximum of one hour after the departure of the passenger's flight, after which they will be deleted. Where the Service is accessed through the installation of the App on the passenger's mobile device, the biometric data relating to facial characteristics may also be stored in the device memory in use for the time the App is installed, in order to speed up the use of the System for flights subsequent to the first one, without prejudice to the possibility for the passenger to delete them at any time.

This does not affect ADR's retention of data relating to passing through airport gates (gate code, date and time of passing) in compliance with the security obligations incumbent on ADR as manager of an airport.

The GDPR (art. The GDPR (articles 15-22) guarantees passengers, as data subjects, the right to request access to personal data concerning them and - where the conditions are met - the portability of the data provided if they are the subject of automated processing based on consent or on the contract; the rectification and/or integration of data if inaccurate or incomplete; the deletion of personal data or the restriction of processing if the conditions are met; opposition to processing for reasons linked to their particular situation as well as the right to withdraw their consent at any time, without prejudice to the lawfulness of the processing carried out before withdrawal. Furthermore, you have the right to lodge a complaint with the Data Protection Authority pursuant to Article 77 of the GDPR, if deemed necessary for the protection of your rights in this matter.

For further information regarding the aforesaid personal data processing activities and for the exercise of the rights indicated above, passengers may contact Aeroporti Di Roma S.p.A., as Data Controller, with registered office at Via Pier Paolo Racchetti 1 - 00054 Fiumicino (RM), Italy, and/or contact the Data Protection Officer, by sending an email to dpo@adr.it.

Updated on  01/07/2021