From airport immigration gates to digital payment apps, facial recognition technology is becoming part of daily life in the UAE. While it offers speed and convenience, many citizens and residents are asking: What happens to my facial data? Who has access to it? Can I say no?

The good news is — your privacy is protected under the UAE’s Personal Data Protection Law (PDPL). In this blog, we break down what facial recognition data is, how the UAE regulates it, and what rights you have to stay in control of your identity.

What Is Facial Recognition Data?

Facial recognition data refers to a type of biometric informationthat is specifically extracted from the unique features of an individual’s face. This data is used by facial recognition systems to identify or verify a person’s identity with a high degree of accuracy. Unlike passwords or ID cards, which can be lost or stolen, facial biometric data is tied directly to your physical identity, making it a powerful tool for both security and convenience — but also one that carries significant privacy risks if not properly protected.

So, what exactly does facial recognition data consist of? It goes beyond a simple photograph. Facial recognition technology analyzes various distinctive characteristicsof your face to create a digital template — a mathematical representation of your facial features — which can then be compared with other templates stored in a database.

Here are some of the most common elements included in facial recognition data:

1. Facial Geometry

This includes the spatial relationship between various points on your face, such as the distance between your eyes, the width of your nose, the shape of your cheekbones, and the contour of your jawline. These measurements are unique to every individual and form the core framework for biometric identification.

2. Unique Facial Features

Every person has a combination of features that makes their face distinct — such as dimples, scars, birthmarks, or the shape of their eyebrows. Advanced recognition systems can capture and analyze these traits to enhance the accuracy of identification.

3. Skin Texture

Modern facial recognition tools also look at the micro-patterns and texture of the skin. This includes the pores, fine lines, and other subtle skin characteristics that are difficult to alter or replicate, making this data highly reliable for verifying identity.

4. Iris and Eye Details

Some systems incorporate iris recognition — a form of biometric identification that focuses on the complex patterns within the colored part of the eye. In combination with other facial features, eye details further increase the system’s precision and security.

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Why Does It Matter?

Facial recognition data is considered sensitive personal dataunder most privacy laws — including the UAE’s Personal Data Protection Law (PDPL). This is because biometric data, unlike other forms of personal information, cannot be changed. If it’s compromised, the risks are long-lasting and difficult to mitigate.

Businesses, government agencies, and technology providers using facial recognition must therefore take extra precautions. Under the PDPL, they are required to inform individualsclearly about how their facial data is being collected, stored, used, and shared. Consent is often a key requirement, and additional safeguards must be in place to prevent unauthorized access or misuse.

This type of data is classified as “sensitive personal data” under the UAE PDPL because it can uniquely identify an individual.

🔐 Why it matters: If mishandled, facial recognition data can be used for unauthorized surveillance, identity theft, or profiling.

The Legal Shield: UAE Personal Data Protection Law (PDPL)

The UAE introduced the Federal Decree-Law №45 of 2021 on the Protection of Personal Data (PDPL) to give individuals greater control over their personal information — including biometric and facial recognition data.

Here’s how the PDPL safeguards your privacy:

Facial recognition data is categorized as “sensitive personal data,” which means it:

• Requires stricter protection than regular personal data
• Cannot be processed unless a legal basis is established
• Must be handled with appropriate technical and organizational safeguards

📌 Takeaway: Companies need your clear consent or a lawful reason to collect and use your face data.

How Is Your Consent Handled?

Under the UAE PDPL, explicit consent is the cornerstone for processing facial recognition data.

Consent must be:

✅ Freely given
✅ Specific to the purpose
✅ Informed (you must understand how your data will be used)
✅ Withdrawable at any time

❌ What doesn’t count? Pre-ticked boxes, silence, or inactivity.

💡 Example: If a mall installs facial recognition for security, they must inform you and give you the option to opt out unless required by law.

When Can Your Facial Data Be Collected Without Consent?

There are limited exceptions where your face data can be processed without consent:

• Public interest or national security
• Healthcare emergencies
• Compliance with a legal obligation

However, even in such cases, data minimization and strict security protocols must be followed.

Data Subject Rights: You’re in Control

The UAE PDPL grants you several rights over your facial recognition data:

🎯 Pro Tip: Always check for a privacy notice or consent form before using a facial scan-based app or device.

Cross-Border Transfers: Is Your Data Leaving the UAE?

Facial recognition data can only be transferred outside the UAE if the destination country ensures adequate protection or if specific safeguards are in place, such as:

• Data Office approval
• Binding legal agreements
• Specific data transfer mechanisms (to be detailed in Executive Regulations)

🚨 Caution: If your facial data is stored on foreign servers (e.g., via cloud apps), ask the provider how and where your data is processed.

Who Regulates and Enforces the Law?

The UAE Data Office oversees and enforces compliance with the PDPL. It is responsible for:

• Approving cross-border data transfers
• Investigating data breaches or misuse
• Issuing fines and corrective actions

As of now, fines for non-compliance have not been officially specified, but are expected in upcoming Executive Regulations.

Real-World Example: Face Scans at Airports

The UAE has implemented facial recognition at airports to streamline passenger verification. While this is legally allowed under national security and public interest grounds, authorities must still:

• Inform passengers about the use of face scanning
• Implement high-level cybersecurity protections
• Minimize data storage duration

✈️ Tip: Look for signage and consent notices at immigration checkpoints or use alternative options where available.

Final Thoughts: Privacy and Progress Can Coexist

Facial recognition isn’t going anywhere — but that doesn’t mean your privacy is up for grabs. The UAE’s PDPL ensures that businesses and government agencies can only use your face data lawfully, securely, and transparently.

As a resident or visitor in the UAE, you’re protected. Just remember:

• Read privacy notices carefully
• Ask questions if you’re unsure
• Use your rights when needed

Need Help Complying with UAE PDPL?

Whether you’re a business using facial recognition or an individual concerned about your data, our privacy experts can guide you through compliance and rights management. Contact us today for tailored support.