Law note · Slovenia
ZVOP-2 Chapter 4 (Articles 81-84) and Article 80, Biometric and Genetic Data
ZVOP-2 Part II Chapter 4, Processing of Personal Data Using Biometrics and Genetic Data, imposes a default prohibition rather than a bare General Data Protection Regulation (GDPR) Article 9 lawful-basis test, read verbatim: Article 81(1) states processing of biometric personal data contrary to this chapter's provisions is prohibited; Article 81(2) requires any other law authorizing biometric processing to itself set the conditions of use; Article 81(3) bars linking biometric-data collections with other collections, or enabling their GDPR Article 20 portability, except where another law provides otherwise.
Separately, in Chapter 3 (Video Surveillance), Article 80 bans, on public surfaces, automated license-plate-recognition systems and systems processing biometric personal data, backed by Article 105 fines of EUR 5,000 to 30,000. Article 80 is entirely a public-video-surveillance provision; it does not carry a collective-redress or representative-action mandate, correcting a commentary-sourced first pass that speculated it did.
No voiceprint-specific definition was located in the sections read; ZVOP-2's own Article 3 definitions section was not read in this pass.
What it asks of an app
- Treat biometric-data processing in Slovenia as prohibited by default under ZVOP-2 Article 81 unless another Slovenian law both authorizes it and sets its conditions of use; a bare General Data Protection Regulation (GDPR) Article 9(2) basis alone is not sufficient in this jurisdiction.
- Do not deploy automated license-plate recognition or a biometric-recognition system on a public surface in Slovenia; ZVOP-2 Article 80 bans this outright, with fines up to EUR 30,000 under Article 105.
When LexLint raises it
Declared activities: processes_biometrics, processes_voice, high_risk_decisions
Primary source: ip-rs.si, ZVOP-2 Arts. 80-84, 105 (direct fetch, verbatim)