Law note · Greece
GDPR Article 9 and Law 4624/2019, Special Categories in Greece
General Data Protection Regulation (GDPR) Article 9(1) classifies biometric data processed for unique identification as a special category. Secondary commentary (Centraleyes, Practical Law) describes Law 4624/2019 as adding a derogation grouping genetic, biometric, and health data together, permitting their processing where necessary for social security or social protection purposes, or to assess an employee's fitness for work.
The HDPA's own official translation PDF did not extract through WebFetch this pass, so the provision's exact article number and whether it enumerates biometric modalities individually are not independently confirmed and are not asserted; the grouping itself is recorded at medium confidence, commentary sourced. No Greece-specific voiceprint or faceprint case or regulatory guidance was located.
What it asks of an app
- Ground the processing of any biometric identifier of a person in Greece, including a faceprint or voiceprint captured for unique identification, on a General Data Protection Regulation (GDPR) Article 9(2) condition such as explicit consent, unless the processing falls within Law 4624/2019's social-security or employment-fitness derogation for grouped genetic, biometric, and health data.
When LexLint raises it
Declared activities: processes_biometrics, processes_voice
Primary source: Secondary commentary (Centraleyes, Practical Law), not independently confirmed against Law 4624/2019's own text this pass