Last updated on October 1, 2025
Scottish guidance classifies biometric data as special‑category personal data and sets out law‑based requirements for any school that wishes to use biometric systems; education authorities must carry out Data Protection Impact Assessments, obtain lawful grounds for processing, secure explicit parental/carer consent (or pupil consent where age/competence allows), provide realistic and safe alternative arrangements for pupils who opt out, and limit retention to strictly necessary periods. The guidance requires robust technical and organisational safeguards, designated data‑protection responsibility, regular audits and transparency with parents and pupils; failure to follow this statutory guidance risks enforcement action by the Information Commissioner and other sanctions. Local authorities and schools are advised to consult the updated December 2024 guidance before implementing or keeping any biometric scheme.
12/10/2024