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.

Deployment of automated facial comparison

The municipality of Leiden uses the automated facial comparison when registering Non-Residents Registration (RNI). This algorithm helps the registrant to avoid "look-alike fraud". In exceptional cases, it is also used when there are doubts about identity for first and resettlement in the BRP, naturalisations or issuance of travel documents

Last change on 22nd of July 2025, at 11:43 (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 face comparison has two purposes, namely:

1. Establishing the identity of the identity card applicant to prevent identity fraud; and

2. Keeping the information in the Basic Registration of Persons (BRP) reliable.


Considerations

The deployment of this algorithm helps employees of the civil affairs department determine the identity of the resident at the counter. The facial comparator can determine the biometric features in the face more accurately than the human eye. The municipality deploys this for all Registrations of Non-Residents (RNI). In this process, an employee always makes the final decision. In exceptional cases, it is also deployed when there is doubt about identity when registering or issuing travel documents.

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

Wet basisregistratie personen: 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

Live image of the resident and the image of the identity document.



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

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