Automated face comparison and document control

Municipality of Waterland

Automated facial comparison and document check during first registration in the Basic Registry of Persons (BRP), resettlement applications and naturalisation applications for persons over 18 years old. This algorithm supports the BRP employee to prevent "look-alike fraud" and check authenticity of a document.

Last change on 8th of May 2025, at 11:13 (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

Begin date

Field not filled in.

Contact information

[e-mail]

Responsible use

Goal and impact

The automated document check and face comparator serve three purposes, viz:

1. Establishing the identity of the identity document applicant 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.

It compares the face of the person at the counter with the image in the scanned identity document and indicates with what certainty it is the same person. This supports the BRP employee in establishing identity and helps prevent "look-alike fraud". The "4-eye principle" is used here. The impact is that it increases the reliability of the BRP registration process and supports the BRP employee in making identity determination decisions.

Considerations

The deployment of this algorithm helps the BRP employee establish the identity of the citizen at the counter. It increases the reliability of the process and reduces the risk of identity fraud. At the same time, privacy implications and the role of human decision-making in the process have been carefully considered.

Human intervention

There is always human intervention. The BRP employee decides whether the face scan is used and what is done with the result. The BRP employee is ultimately responsible for the decision on identity determination and possible rejection. Furthermore, the 'four-eye principle' is applied if the finding of the document check or face comparator is negative. Finally, third-line verification can always be called in from the Marechaussee/ Identity Fraud Team.

Risk management

The facial image is recorded in the system only during the identity determination process and is visible only to BRP employees. This limits the risk of data leakage or manipulation. Strict access controls and security measures have been implemented to prevent unauthorised access to the system. Employees are trained to use the system and to recognise potential errors or limitations.

The system is located in a locked department.

Legal basis

BRP Act art. 2.67 4th paragraph: Legal obligation to establish proper identity

BRP Decree art.35

UAVG art. 29: Admissibility of biometrics for authentication

Operations

Data

Biometric features in the face.

Technical design

The system uses deep learning and advanced face recognition APIs. Technical components include:ID scannerA4 scanner Scan server. Small monitor. Facial 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 facial scan with the image from the identity document.

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

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

Only the result of the scan ('The faces are the same' or 'The faces are not the same') is logged in the BRP system.

External provider

ORIBI-ID Solutions ( Link to external page https://oribi.nl )