# Biometric proportionality worksheet

**System:** [for example, fingerprint timeclock at the Hamilton depot]
**Vendor:** [name]
**Owner:** [name]
**Date:** [date]

## 1. What processing happens?

- Type: [verification / identification / categorisation]
- Biometric information used: [face / fingerprint / voice / other]
- Whose: [staff / customers / public], approximately how many people
- Where processing and storage happen, including overseas: [details]
- Are templates or raw images kept? For how long?

## 2. Purpose

What specific problem does this solve? [For example, "buddy punching", where staff clock in for each other, cost an estimated $X last year.]

Is the purpose lawful and connected to our functions? [Yes, explain]

## 3. Necessity and effectiveness

- What evidence shows the problem exists and is significant?
- What evidence shows this system solves it? Include accuracy figures and testing.
- Does it work equally well across ages, skin tones, disabilities and other relevant characteristics? What testing supports that?

## 4. Less intrusive alternatives

| Alternative | Would it achieve the purpose? | Why or why not |
| --- | --- | --- |
| [Swipe card or PIN] | | |
| [Supervisor sign-off] | | |
| [Other] | | |

If an alternative would work about as well, the processing is unlikely to be proportionate.

## 5. Privacy risks

- What could go wrong for individuals (misidentification, exclusion, function creep, breach)?
- Who is most affected, and how badly?
- Any risk of categorising people by sensitive characteristics or inferring emotions, personality or health? (The code restricts this.)

## 6. Benefits

What benefits does it deliver, and to whom? Quantify where possible.

## 7. Safeguards

- [ ] An alternative option for people who don't want to use biometrics
- [ ] Human review before any adverse action based on a match
- [ ] Accuracy testing before go-live and periodically
- [ ] Security: encryption, access controls, vendor security reviewed
- [ ] Retention: templates deleted when no longer needed (for example when staff leave)
- [ ] Notice to people before or when collection happens, including signs where relevant
- [ ] Overseas processing assessed against the code's conditions
- [ ] Contract with vendor covers all of the above

## 8. Conclusion

**Is the processing necessary, effective and proportionate, with adequate safeguards?** [Yes / No, with reasons]

**Decision:** [proceed / proceed with changes / stop and delete templates]

**Approved by:** [name, role, date]
**Review date:** [date]

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From Faraday, faraday.co.nz/templates/biometric-assessment/ (CC BY 4.0). Checked against New Zealand sources on 19 October 2026. General information, not legal advice.