Law note · Bangladesh

Personal Data Protection Act, 2026, sensitive personal data and biometric data

cite Personal Data Protection Act, 2026, Act No. 63 of 2026, s.2(21), s.2(14), s.7 stage RECENT in force 10 months effective 2025-11-06 kind Sensitive categories binds public and private bodies reviewed 2026-08-29

What it requires

An app that derives a facial image, voiceprint, or other biometric identifier from a person in Bangladesh must treat it as Sensitive Personal Data and satisfy one of section 7's narrower lawful-basis conditions, ordinarily the data principal's specific consent, before processing it.

When LexLint raises it

processes_biometrics
processes_voice
crawls_web
trains_models

Excludes recording-derived identifiers: No

What we found

Biometric Data is defined (definitions item 14) as personal data created through measurement or technical processing of a person's physical, physiological or behavioral characteristics, capable of uniquely identifying a specific person, expressly naming DNA, blood group, fingerprint, facial image, iris scan, voiceprint, and gait pattern as examples.

It is one of the enumerated Sensitive Personal Data categories (item 21), alongside genetic data, ethnic and community data, political or religious belief, trade union membership, health data, sexual orientation, criminal-record data, and real-time geolocation data.

Section 7 processing conditions for sensitive data are narrower than the ordinary section 5(3) legitimate-interest grounds: specific consent, contract necessity, an employment or social-security legal duty, a health worker's treatment duty or life or health emergency, a duty imposed by law, or the data principal's own voluntary public disclosure of the data.

Primary source

official statute text, Bangladesh Laws (bdlaws.minlaw.gov.bd), via an Internet Archive capture since the official portal serves no HTTPS

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