Typical project · Quebec and Ontario
Facial recognition at the doors of a server room and a records room, planned around consent
These are typical projects, described from the kind of work we do. They do not describe a named client or a specific building.
A card proves that someone holds the card, not who they are. This is how face recognition readers are added at two sensitive doors within Quebec's rules on biometrics: only where needed, only with consent, and with another way in for anyone who declines.
The situation: cards that are lent, and two doors where that is not enough
The client is a company whose offices include a server room and a records room holding its clients' files. Both doors have card readers, but cards get lent or left on desks, and the log cannot say who really went in.
Management asks for facial recognition at those two doors. It also knows that biometrics are strictly regulated in Quebec: the company must justify the need, obtain consent, declare the system to the Commission d'accès à l'information and assess the effect on privacy. It wants the system built around those duties from the start.
What the first visit to the two doors finds
- Two doors, a short list of peopleOnly a handful of employees need these two rooms; everyone else keeps a card.
- A card system that takes another readerThe existing access control accepts other reader types at those two doors; the rest of the building and its cards stay as they are.
- Door hardware that decides the resultOne door closes poorly and its lock gives way to a shoulder. A reader is of little use until the door, the lock and the door contact are sound.
- A question nobody has asked yetWhere facial data would be kept, who could see it and when it would be deleted is undecided, and the answers shape what must be declared.
What is designed, and why
The design starts from the reason for the biometrics and from the person who says no.
- Biometrics only where the need is realFace readers go only at the two doors where a lent card is a real, documented risk; convenience alone does not justify biometrics. Every other door keeps its card reader.
- Express consent and another way inEach person is enrolled only after written, express consent. Anyone who declines, or later withdraws, gets a card and personal code at the same doors with the same access. Nobody loses access for saying no.
- The least data, in the fewest placesThe reader keeps a numerical template of the face, not a photograph, where the equipment allows, and only for enrolled people. Whether templates live in the reader, on a server or on the person's card is decided with the client: it changes what must be declared.
- Readers that verify, not cameras that watchIdentity is checked at the door, for enrolled people who face the reader knowingly. The corridor cameras recognise no one here; recognition on cameras is a separate question.
- A protected system and a short retentionThe access server and the readers sit on a separate network segment, administrator access is limited and logged, and a template is deleted when its person leaves, changes role or withdraws consent.
How the work is sequenced so that nobody is enrolled too early
No face is enrolled before the client's privacy work is done; the cards keep working throughout.
- The facts for the client's privacy file
We describe in writing what the readers capture, where templates are kept, who can reach them and how long they stay before deletion. The client and its advisers use it for the privacy impact assessment and the declaration to the Commission; a database of biometric characteristics must be declared at least sixty days before it is put into service.
- Doors put right while the cards still work
The weak door is adjusted, the lock and the contact are replaced where needed, and the new readers are mounted and wired beside the card readers.
- Notice and consent forms
Each person concerned receives a plain-language notice and a consent form prepared by the client. The card and code alternative is ready for anyone who declines.
- Enrolment by appointment
Each consenting person is enrolled in a short private session and tries the door at once. Withdrawal is tested too: the template is deleted and the card and code take over.
- Switch-over on the agreed day
On the date the client chooses, a card alone stops opening those two doors; the face, or the card with its code, does. Forced-door and door-held alarms are tested.
What is handed over
- The written technical description for the privacy impact assessment and the declaration
- The list of doors and how each one opens: face, card and code, or card
- The procedure for enrolling, withdrawing consent and deleting a template
- The retention and deletion settings, as configured
- The record of the tests of each door, reader and alarm
- Administrator access and the network diagram of the access system, in the client's name
Services involved
Industry
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A project like this starts with the reason for the biometrics
Tell us which doors worry you and why, how many people need them and what access system you have. We visit the doors, then send a quote with the readers, the alternative and the technical facts your privacy advisers will need. This page is not legal advice: the obligations are the client's, and its advisers confirm them. Outside Quebec, other privacy laws apply. We reply in English or French.