It also suggests that the accuracy of biometrics as a unique identification key is “overestimated” and will “facilitate unwarranted interconnection of databases”.
The warning was issued on 13 March in response to a European Commission communication published in November last year, which focused on the interoperation of three data systems currently in operation in the EU. These are the second-generation Schengen Information System (SIS II), which allows Member States to exchange information relating to border controls; the Visa Information System (VIS), which aims to improve visa issuing procedures; and EURODAC, a system used to compare fingerprints of asylum applicants and illegal immigrants. The communication’s premise was that these systems could more effectively support policies linked to the free movement of persons and help to combat terrorism and serious crime.
In his statement, Peter Hustinx of the EDPS said: “The Commission argues that interoperability is a technical rather than a legal or political concept. This is confusing and only serves to avoid fundamental issues.” He continued: “Interoperable systems increase the risks for citizens, if such systems allow for new access to their personal data. It is essential to examine this more carefully and not hide it as a technicality.”
And the communication’s promotion of using biometrics as a primary key – a unique number produced for every item on which information is gathered and stored in a database – is also criticised. According to the EDPS, biometrics “will not deliver the unambiguous key that is, by definition, required for primary keys of databases,” suggesting that their use is likely to lead to “a breach of the principle of data quality”.