Konferenzbeitrag
Research, the GDPR, and Mega Biometric Training Datasets: Opening the Pandora Box
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2022
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Gesellschaft für Informatik e.V.
Zusammenfassung
This paper sheds light on the challenges that the EU data protection rules pose to the
constitution and the use of large-scale biometric datasets for research purposes. The paper analyses
the GDPR (General Data Protection Regulation) rules applicable to research and explains their
inadequacy for the constitution of large biometric datasets developed to train and test biometric
recognition models. Researchers need a considerable amount of data to train and test their models.
These data cannot be realistically obtained with the consent of individuals to whom the data relate.
But can researchers collect them from publicly available sources, such as social media or open
platforms, to create large biometric datasets? Under the current GDPR rules, it seems rather
difficult for researchers located in the EU to do so. A thorough analysis of the provisions will
explain the challenges that researchers face. In that context, one could have hoped that the Data
Governance Act (DGA) would have brought some opportunities for research when it aimed at
promoting data altruism. But it seems that the DGA is a missed opportunity to open up personal
data for research purposes. As acknowledged by some companies, these regulatory impediments
might force researchers to train their models outside the EU with datasets not subject to the EU
data protection rules.