Law note · Israel
Protection of Privacy Law, biometric identifier definition and security-level tiering
What it requires
- An app that captures or stores a facial image, voiceprint, or other biometric identifier of a person in Israel, including one derived from a photo, video, or audio recording, must treat it as data of special sensitivity and apply Israel's tiered security-level obligations, which scale up automatically at 100,000 or more biometric identifiers held.
When LexLint raises it
processes_biometricsprocesses_voice
- Excludes recording-derived identifiers
- No
What we found
Art. 3 defines data of special sensitivity to include, among eight-plus enumerated categories, a biometric identifier used or intended to be used to identify a person or verify his identity in a digital manner, itself defined as a biometric data item used to identify a person or verify that person's identity, or a biometric measure from which the said data item can be derived, where biometric means a unique human, physiological, or behavioral characteristic that can be measured through digital measurement.
The derivation clause affirmatively brings in an identifier derived from a recording; a facial image is confirmed within scope by a separate security-level provision that gives a biometric identifier limited to a facial image a lighter basic-security-level treatment only when confined to internal employee or supplier management, a security-tier carve-out, not a substantive consent exemption.
Chapter D3/D4 imposes tiered security-level obligations keyed partly to biometric-identifier volume, automatically classifying a database of 100,000 or more biometric identifiers as high security level. No voice-specific provision or dedicated biometric retention or destruction duty was found; Art. 2(6) separately prohibits commercial use of a person's name, image, or voice without consent as a distinct tort, outside the database regime.