DPE-2026-0018

Document verder uitgelezen dan de controle

Een identiteitscontrole legt het hele document vast waar de vraag aan een fractie genoeg had.

Familie
Gegevens
Status
actief
Geldt voor
mobile-app, web, api

Wat er gebeurt

To answer a narrow question, such as whether someone is over eighteen or whether a name matches, the system photographs or chip-reads the document in full and transmits everything it obtained: the complete machine-readable zone, the portrait image, the security object, the document number, the nationality. The relying party frequently receives, and needs, only a yes or no.

Waarom het ertoe doet

The person shows a document to answer one question and hands over a permanent dossier instead: a face image usable for recognition, numbers that never change, and a nationality that was nobody's business. The gap between what was asked and what was taken is invisible at the moment it happens, because the interaction looks like holding a card against a phone.

Veelvoorkomende oorzaken

  • a verification component that reads all available data groups because the reader supports them
  • the whole capture uploaded for server-side processing, with the narrowing done afterwards
  • an image retained as proof of the check rather than the result of the check
  • the comparison performed by a remote service, so the image travels even where the device could do it

Dit is het níet

An ordinary identity check, where a person shows a document and a human or a system compares it, is not this entry. Nor is a chip read that stays on the device and yields only a derived answer. The distinguishing feature is that material beyond what the question needs leaves the device.

Hoe je het vaststelt

Indicator

The upload during a check contains fields or files beyond those needed for the stated question: a portrait image or a complete machine-readable zone where the result exposed to the relying party is a single attribute or a boolean. The comparison between what was transmitted and what the result contains is the finding.

Methode

network-with-identifier

Kwaliteit van de detectie

85 van 100

De grenzen van deze bevinding

Wat dit patroon zou weerleggen

  • The relying party needs the full data set for a task set out in law, such as a statutory identification duty.met de hand te toetsende bevinding vervalt
  • All processing happens on the device and only the derived answer leaves it.machinaal te toetsende bevinding vervalt
  • The extra fields are needed to verify the authenticity of the document itself.met de hand te toetsende bevinding wordt zwakkerAuthenticity checking can require the security object. That justifies reading it, not retaining it, and the two are separate questions.
  • The person was offered a check that reads less and chose the wider one.met de hand te toetsende bevinding wordt zwakker

Wat dit patroon níet vaststelt

  • harm; the catalogue standardises a finding so it can be referred to, it does not weigh it
  • severity; there is no score here, by design. Weighing belongs to whoever applies the entry to a concrete case
  • unlawfulness; that is for a supervisory authority or a court
  • intent; a fault is usually a build decision, not a plan
  • absence: not finding it in one capture is not evidence that it is not there

Reproduceren

  • manualMETHOD.mdno dedicated reproduction exists yet; follow the general method and the indicator above

Juridisch kader

Bepalingen

eu-gdpr-5-1-ceu-gdpr-9-1eu-gdpr-13

Veelgehoorde tegenwerpingen

We need the document to establish that the person is who they claim.

That is the question, and the question can be answered with the answer rather than the source material. Reading in full and narrowing afterwards is a design choice, and the transfer has already happened by then.

The portrait is only used for the comparison.

A face image processed for unique identification is a special category regardless of how briefly it is used. Use and category are separate questions.

The consent screen explained it.

Test that. Compare the field list the person was shown with the field list in the payload; where the second is longer, the explanation was not of this processing.

The comparison has to happen in the cloud.

That is a build decision, not a necessity: comparison on the device is demonstrably possible. Where it happens remotely, the sample leaves and the transfer question follows it.

Geldt wanneer

to-processing

Aangetroffen in

De onderzoeken waarin dit patroon gemeten is.

Verwante patronen

← alle patronen