Face Risk Assessment

Face Risk Assessment Template for Ireland

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Key Requirements PROMPT example:

"I need a Face Risk Assessment for implementing a facial recognition access control system at our Dublin-based financial services office by March 2025, ensuring compliance with Irish banking regulations and GDPR requirements for approximately 500 employees."

Document background

The Face Risk Assessment is a mandatory document required when implementing facial recognition technology in Ireland, particularly under the Data Protection Act 2018 and GDPR requirements for processing special category (biometric) data. This document becomes necessary when an organization plans to deploy facial recognition systems, whether for security, access control, or other business purposes. It comprehensively addresses privacy implications, technical specifications, security measures, and compliance requirements specific to Irish law and EU regulations. The assessment must be conducted before implementing facial recognition technology and updated periodically or when significant changes occur. It forms a crucial part of an organization's data protection documentation and demonstrates compliance with privacy-by-design principles required under Irish and EU data protection frameworks.

Suggested Sections

1. 1. Executive Summary: Overview of the facial recognition system being assessed and key findings of the risk assessment

2. 2. System Description: Detailed description of the facial recognition technology, its purpose, scope, and technical specifications

3. 3. Legal Framework: Applicable laws, regulations, and standards governing the use of facial recognition technology in Ireland

4. 4. Data Processing Information: Details of how facial data is collected, processed, stored, and protected

5. 5. Risk Assessment Methodology: Description of the approach and criteria used for identifying and evaluating risks

6. 6. Risk Analysis: Detailed analysis of identified risks, including privacy, security, discrimination, and technical risks

7. 7. Impact Assessment: Evaluation of potential impacts on individuals' rights and freedoms

8. 8. Risk Mitigation Measures: Specific controls and measures to address identified risks

9. 9. Compliance Requirements: Specific steps and measures needed to ensure compliance with relevant regulations

10. 10. Monitoring and Review: Procedures for ongoing monitoring and periodic review of the risk assessment

Optional Sections

1. Vendor Assessment: Required when using third-party facial recognition technology, evaluating vendor security and compliance measures

2. Cross-border Considerations: Required when facial data may be transferred outside of Ireland or the EU

3. Special Category Processing: Required when the system specifically processes data related to children or vulnerable groups

4. Integration Assessment: Required when the facial recognition system integrates with other systems or databases

5. Employee Training Requirements: Required when system operators need specific training or certifications

Suggested Schedules

1. Appendix A: Technical Specifications: Detailed technical documentation of the facial recognition system

2. Appendix B: Data Flow Diagrams: Visual representations of how facial data moves through the system

3. Appendix C: Risk Matrix: Detailed risk scoring and evaluation matrices

4. Appendix D: Control Framework: Comprehensive list of technical and organizational controls

5. Appendix E: Compliance Checklist: Detailed checklist for ensuring compliance with all relevant regulations

6. Appendix F: Incident Response Plan: Procedures for handling security incidents or data breaches

7. Appendix G: Review Log: Documentation of risk assessment reviews and updates

Authors

Alex Denne

Head of Growth (Open Source Law) @ ��Ƶ | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

alex.den.21@genieai.co

Relevant legal definitions

Clauses

Relevant Industries

Financial Services

Healthcare

Security and Surveillance

Retail

Technology

Transportation and Logistics

Government and Public Sector

Education

Manufacturing

Hospitality

Corporate Office Facilities

Research and Development

Relevant Teams

Legal

Information Security

Data Protection

IT Operations

Risk Management

Compliance

Privacy

Technical Operations

Security Operations

Project Management

Infrastructure

Governance

Relevant Roles

Data Protection Officer

Chief Information Security Officer

Privacy Manager

Compliance Manager

Risk Assessment Specialist

Information Security Manager

IT Director

Chief Technology Officer

Legal Counsel

Security Operations Manager

Systems Administrator

Privacy Analyst

Compliance Officer

Risk Manager

Technical Project Manager

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Authors

Alex Denne

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