Is a fingerprint or a face personal data?
Yes. The CNDP defines biometric data as any information that identifies a person by physical, biological or behavioural characteristics that are unique and near-permanent. It therefore falls under law 09-08, with stricter rules than a simple badge number, because it can reveal other information, about health for example.
A badge without biometrics (RFID card, PIN code) is still personal data processing, but is not subject to the rules specific to biometrics.
What do the CNDP fact sheets say about biometrics?
The two CNDP fact sheets set four conditions for a biometric access control system.
Sites that justify it
Premises with major security stakes, where other control methods are not reliable enough.
Never the raw data
Only a template of characteristic points is kept; the raw image only for the time of extraction.
On a medium the person holds
The template is stored on a card that only the employee holds.
A central database by exception
Reserved for highly sensitive sites, and cleared as soon as a person no longer has access.
What must the employee information notice contain?
Handed over before collection, it states at least:
- the identity of the organization;
- the fact that it processes biometric data;
- the purpose of the processing, including counting working hours;
- the contact for exercising rights of access, rectification and objection;
- the CNDP authorization number.
How long should biometric data be kept?
The raw image is kept only for the time needed to extract its characteristics, and a person’s data is deleted as soon as they no longer have access to the sites. For time and attendance: remove the fingerprint or face when the employee leaves, and cover any provider that accesses the data with a contract.
What options are there to clock in with less biometric data?
| Option | Biometric data | What you need to know |
|---|---|---|
| RFID badge or PIN code only | None | No biometric rules; badges can be lent, which anomaly analysis helps detect. |
| Clocking in by phone (GPS, zone, selfie) | No recognition: the selfie is a photo attached to the punch | Location and photo are still personal data: employees must be informed. |
| Biometrics with the template on the employee’s card | Yes, on a medium the employee holds | The architecture described in the CNDP fact sheets. |
| Fingerprint or face time clock, templates in the device | Yes, in the time clock | To be described in the authorization request. |
| Central template database | Yes, on a server | Exceptional according to the fact sheets, reserved for highly sensitive sites. |
RFID badge or PIN code only
- Biometric data
- None
- What you need to know
- No biometric rules; badges can be lent, which anomaly analysis helps detect.
Clocking in by phone (GPS, zone, selfie)
- Biometric data
- No recognition: the selfie is a photo attached to the punch
- What you need to know
- Location and photo are still personal data: employees must be informed.
Biometrics with the template on the employee’s card
- Biometric data
- Yes, on a medium the employee holds
- What you need to know
- The architecture described in the CNDP fact sheets.
Fingerprint or face time clock, templates in the device
- Biometric data
- Yes, in the time clock
- What you need to know
- To be described in the authorization request.
Central template database
- Biometric data
- Yes, on a server
- What you need to know
- Exceptional according to the fact sheets, reserved for highly sensitive sites.
Common options, from most to least protective with regard to biometrics.
How does TEMPO handle biometric data?
TEMPO does not build a central fingerprint database: templates stay in the time clocks, and TEMPO neither displays nor exports them. On an employee’s leaving date, they are removed from the time clocks. Actions on the time clocks are recorded in the activity log.
Where biometrics are not justified, TEMPO also works with a badge, a PIN code or clocking in by phone. See also data security.
Questions fréquentes
Are biometric time clocks legal in Morocco?
They are not prohibited, but they are regulated by law 09-08. According to the CNDP fact sheets, a biometric system requires a prior authorization request, the employer must justify that other methods are not enough, and employees are informed by a notice stating the purpose of the processing.
Which documents for the CNDP authorization request?
The CNDP fact sheets list a description of the biometric system, an undertaking to comply with deliberation n° 478-2013 and law 09-08, a template information notice for the people concerned, and a document proving signing authority (commercial register or articles of association). Check the up-to-date forms on the CNDP website.
Where are fingerprints stored with TEMPO?
In the time clocks. TEMPO keeps no central fingerprint database and neither displays nor exports them. When an employee leaves, on the leaving date entered in their record, they are removed from the time clocks. Actions on the devices are restricted to authorized roles and recorded in the activity log.
Can employees clock in without biometrics?
Yes. TEMPO accepts RFID badges, PIN codes on the time clock and clocking in by phone with location, an authorized zone and, if you require it on a site, a selfie attached to the punch. These methods avoid the rules specific to biometrics, but are still personal data processing that employees must be informed of.
Sources
Textes officiels d'où viennent les chiffres de cette page. Les valeurs proposées par le logiciel restent modifiables.