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REGULATORY COMPLIANCE · GDPR

Every data subject right is operationally supported not just written into a policy

Biometric data and identity documents are Article 9 special category personal data under GDPR, the most tightly regulated data category in EU law. Shufti processes this data under a documented legal basis, retains it only as long as you configure, and operationally supports every data subject right your users may exercise. Shufti GDPR Data Processing Agreement is included in the standard enterprise contract, not an optional add-on.

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What GDPR Covers

GDPR applies to any organisation processing personal data of EU residents. It distinguishes between standard personal data and special category data, each with different obligations. For identity verification providers, this distinction is critical.

Standard Personal Data

Name, email address, phone number, IP address, regulated under GDPR Articles 5 and 6. Requires a lawful basis for processing, reasonable security measures, and data subject rights. Most SaaS platforms operate under this category.

Article 9 Special Category Data

Biometric data used to uniquely identify a person, facial images, and identity document data, the most tightly regulated GDPR category. Requires explicit consent or legal obligation as processing basis, stricter security controls, mandatory data minimisation, full data subject rights support, and a documented Data Protection Agreement before any processing begins.

Why It Matters

Supervisory authorities, Italy's Garante, Ireland's DPC, and France's CNIL, have specifically investigated digital onboarding flows where verification providers retained biometric data beyond necessity, lacked a documented processing basis, or could not operationally support data subject rights. Enforcement actions followed against the businesses that contracted with those providers.

When a user exercises their right to erasure

Your team needs to operationally deliver it, not just acknowledge it. Shufti's API and admin console let you trigger deletion of individual verification records and receive a deletion confirmation as your audit evidence.

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EUR 1.2B+

GDPR enforcement fines, 2023-2024, with biometric data in onboarding flows a specific focus. The liability sits with the controller, which is you. Shufti's DPA and deletion controls are how you close that exposure.

How Shufti Maintains IT

Shufti GDPR documentation package includes: the Article 28-compliant DPA, sub-processor register (updated within 30 days of any change), data retention and deletion policy, and technical documentation of how data subject rights are operationally supported. All available on request before you sign a contract.

EU-resident data is processed on EU infrastructure. UK-resident data is processed under UK GDPR. US and APAC regional deployments are available for non-EU data flows.

Certification Details

Legal basis

GDPR Article 28 (processor); Article 9(2)(a) or 9(2)(b) processing basis configured by controller.

Included as standard

GDPR-compliant DPA in every enterprise contract, no separate negotiation required.

Data residency

EU infrastructure for EU flows; UK, US, APAC regional options available.

Data subject rights

Erasure, access, and portability supported via API and admin console with audit log confirmation.

What you get

DPA, sub-processor register, retention policy, and deletion documentation, available pre-contract.