Law note · Denmark

GDPR Article 9, Special Categories of Personal Data as Applied in Denmark

cite Regulation (EU) 2016/679, Art. 9 stage In effect since 2018-05-25 reviewed 2026-08-24

General Data Protection Regulation (GDPR) Article 9(1) classifies biometric data processed for the purpose of uniquely identifying a natural person as a special category of personal data, prohibited absent an Article 9(2) ground such as explicit consent.

No Danish statutory enumeration or illustrative list of biometric identifier types was confirmed this pass, and none is asserted; Datatilsynet has engaged case by case with facial recognition deployments through its authorization and guidance practice, but no voiceprint specific guidance or enforcement decision was located.

What it asks of an app

  • Ground the processing of any biometric identifier of a person in Denmark, including a faceprint or voiceprint captured for unique identification, on a General Data Protection Regulation (GDPR) Article 9(2) condition such as explicit consent.

When LexLint raises it

Declared activities: processes_biometrics, processes_voice

Primary source: Official Journal text, EUR-Lex, Regulation (EU) 2016/679

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