Oribi

Municipality of Lansingerland

Facial comparison is a tool used by municipalities to establish people's identity. This is often done at the municipal counter.

Last change on 4th of February 2026, at 10:16 (CET) | Publication Standard 1.0

• Publication category: Other algorithms
• Impact assessment: DPIA
• Status: In use

General information

Theme

Organisation and business operations

Begin date

Juli

Contact information

[e-mail]

Responsible use

Goal and impact

The algorithm supports the employee at the counter in comparing a live captured facial image with the image on an identity document. The employee is shown an indication and possibly comparison score, based on which he or she can make the assessment that person and document belong together. The aim is to prevent identity fraud (such as look-alike fraud) and strengthen the reliability of data in the BRP.

Considerations

The algorithm is a tool and supports visual verification. It contributes to careful identity determination without replacing human judgement.

Human intervention

The employee decides whether to use the face scan and assesses the result. If in doubt, a colleague is consulted (four-eye principle).

Risk management

No biometric data is stored. The full face comparison is performed locally within the secure municipal infrastructure; no biometric data or other data is transmitted over the internet or stored externally. The facial comparison is temporary and visible only to authorised employees. The application is standardised for all citizens and includes access controls, reducing the risk of profiling or unlawful processing.

Legal basis

BRP Act Art. 2.67(4); BRP Decree Art. 35; UAVG Art. 29 - deployment of biometrics is allowed in case of necessary authentication.

Links to legal bases

https://wetten.overheid.nl/BWBR0033715/2023-10-01: Hoofdstuk2, Wet BRP art. 2.67 lid 4; Besluit BRP art. 35; UAVG art. 29 – inzet van biometrie is toegestaan bij noodzakelijke authenticatie.

Impact assessment

Data Protection Impact Assessment (DPIA): In uitvoering

Operations

Data

Live image of the citizen and the image of the identity document (e.g. photo on chip or MRZ).

Technical design

The algorithm uses face comparison based on deep learning technology. It is integrated into the counter application and uses underlying APIs (e.g. C++, Java, .NET, BioAPI 2.0). A comparison score is generated and no biometric data is stored. Local processing is involved.

External provider

Oribi B.V. - https://www.oribi.nl