Please note: The algorithm descriptions in English have been automatically translated. Errors may have been introduced in this process. For the original descriptions, go to the Dutch version of the Algorithm Register.

Use of automated facial comparison

The municipality of Leiden uses automated facial recognition when registering non-residents (RNI). This algorithm helps the registrar to prevent ‘look-alike fraud’. In exceptional cases, it is also used where there is doubt regarding identity in connection with initial and re-registrations in the BRP, naturalisations or the issue of travel documents.
Last change on 17th of June 2026, at 6:38 (CET) | Publication Standard 1.0
Publication category
Impactful algorithms
Impact assessment
DPIA
Status
In use

General information

Theme

Organisation and business operations

Begin date

2021-09

Contact information

algoritmes@leidse-regio.nl

Responsible use

Goal and impact

Automated facial recognition serves two purposes, namely: 

1. To establish the identity of the applicant for an identity document in order to prevent identity fraud; and 

2. To ensure the accuracy of the information in the Basic Register of Persons (BRP). 

  


Considerations

The use of this algorithm helps staff in the Civil Affairs Department to verify the identity of residents at the counter. The facial recognition system can identify biometric features in the face more accurately than the human eye. The local authority uses this system for all Non-Resident Registrations (RNI). In such cases, a member of staff always makes the final decision. In exceptional cases, it is also used where there is doubt about a person’s identity during registration, naturalisation or the issue of travel documents. 

Human intervention

The employee decides for themselves whether to use the facial scan and assesses the result. In case of doubt, a colleague is consulted (four-eyes principle).

Risk management

No biometric data is stored. The entire facial comparison is carried out locally within the secure municipal infrastructure; no biometric data or other data is transmitted via the internet or stored externally. The facial comparison is temporary and visible only to authorised staff. The application is standardised for all citizens and includes access controls, thereby limiting the risk of profiling or unlawful processing.

Legal basis

BRP Act, Article 2.67(4); BRP Decree, Article 35; UAVG, Article 29 – the use of biometrics is permitted where authentication is necessary.

Links to legal bases

The Basic Registration of Persons Act: https://wetten.overheid.nl/BWBR0033715/2023-10-01#Hoofdstuk2

Link to Processing Index

https://leiden.registervanverwerkingen.nl/details/f71c66c7-011e-46b3-8569-8dc4213a7ed9

Elaboration on impact assessments

A DPIA has been carried out

Impact assessment

Data Protection Impact Assessment (DPIA)

Operations

Data

A live image of the resident and a photograph of their identity document.



Technical design

The algorithm uses facial comparison based on deep learning technology. The software is integrated into the counter application and utilises underlying APIs (e.g. C++, Java, .NET, BioAPI 2.0). A comparison score is generated and no biometric data is stored. Processing takes place locally.

External provider

Oribi (https://www.oribi.nl/)

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