Automated document check and face comparison

Municipality of Woensdrecht

Automated document check and facial comparison for registrations in the BRP, applications for travel documents and driving licences, and for reporting removals (intra-municipal and migrations). The tool checks the authenticity characteristics of identity documents and prevents "look-alike fraud".

Last change on 1st of May 2025, at 12:11 (CET) | Publication Standard 1.0

• Publication category: Impactful algorithms
• Impact assessment: Field not filled in.
• Status: In use

General information

Theme

• Organisation and business operations
• Public Order and Safety
• International

Begin date

01-2025

Contact information

[e-mail]

Responsible use

Goal and impact

ID Citizen is a technological tool that supports in preventing identity fraud. It consists of a document reader to check authenticity characteristics of identity documents and a face and passport photo comparison module. This tool verifies whether the person belongs to the identity document and prevents "look-alike fraud".

The automated document check and face comparator serve three purposes, namely: 1. Establishing the identity of the applicant for an identity document to prevent identity fraud; 2. Establishing the authenticity of the source documents supplied from the country of origin to prevent forgery; 3. Keeping the information in the Basic Registration of Persons (BRP) reliable.

If the application, using the algorithm, indicates that the person whose face has been compared with the passport photo is not the person standing at the counter, the counter employee engages a colleague (as a second line) to verify this finding.

These staff apply the 'four-eye principle' when in doubt about a document or face scan finding. If they conclude, partly based on their own assessment and observation, that the finding of a document or facial scan is correct and the identity of the applicant does not match the identity in the photo, the application for registration in the BRP or the application for a travel document or driving licence is rejected. This rejection may indicate whether fraud is suspected. In that case, Police and/or Marechausse are called in for further investigation.

Considerations

The deployment of this algorithm helps employees of the Public Square Team determine the identity of citizens at the counter. Documents contain a number of authenticity features that the document scanner can determine more accurately than the human eye. This also applies to checking the biometric features in the face.

Human intervention

ID Citizen does not replace the expertise of the staff of the Public Square Team, but supports them. No distinction is made in the application of the document scanner and face comparator. Both instruments are deployed for every citizen who comes to register as a resident of Woensdrecht municipality and/or applies for a travel document or driving licence or reports a change of address. Furthermore, the 'four-eye principle' is applied if the finding of the document check or face comparator is negative. Finally, when identity documents are issued, a final check is carried out by a member of the Team Publieksplein desk staff.

Risk management

By always deploying the applications when registering for the BRP and/or applying for a travel document/driving licence or reporting a move, the risk of possible profiling is excluded in advance. The next risk is that the automated document check or face comparator actually leads to an automated decision. This risk is overcome because the finding is always tested by an employee. And in case of doubt by at least two employees ('four-eye principle').

No facial recognition takes place, but a facial comparison. The facial image is only registered in the system during the process of establishing identity and is only visible to BRP employees. No further storage of the facial image takes place.

Oribi ID-Solutions does not process personal data and does not have access to the data.

Legal basis

• Legal obligation to establish proper identity: Article 2.67, fourth paragraph, BRP Act
• BRP Decree art.35
• Admissibility of biometrics for authentication: article 29 UAVG

Links to legal bases

• Wet basisregistratie personen: https://wetten.overheid.nl/BWBR0033715/2025-02-12/
• Uitvoeringswet Algemene Verordening Gegevensbescherming: https://wetten.overheid.nl/BWBR0040940/2021-07-01/0

Operations

Data

Authenticity features of the document and biometric features of the face.

Technical design

The system uses deep learning and advanced facial recognition APIs. Technical components include:

• ID scanner
• A4 scanner
• Scan server
• Small monitor
• Face scanner

The process is as follows:

1. The identity document is scanned.

2. A face scan is made of the person at the counter.

3. The algorithm compares the face scan with the image from the identity document.

4. The result of the comparison is displayed on the monitor.

5. The BRP officer evaluates the result and makes a decision.

External provider

ORIBI-ID solutions (https://www.oribi.nl/nl/producten/id-burger)