Purpose of the Template
You're integrating fingerprint readers, facial recognition, or voice authentication into your payment flow. Your compliance team needs a written policy that addresses how you collect, process, and protect biometric identifiers while meeting PCI DSS requirements and privacy regulations like GDPR.
This template establishes your organization's position on biometric data handling in payment contexts. It's designed for PCI DSS compliance teams who need to document their approach before deploying biometric authentication and satisfy both security assessments and privacy audits.
Biometric authentication meets consumer expectations for instant, seamless transactions. However, it introduces data that's more secure yet more sensitive than passwords. Unlike a compromised PIN, you can't reissue someone's fingerprint.
Prerequisites
Before you customize this template, confirm you have:
- A data classification policy that categorizes Cardholder Data. Extend this to include biometric identifiers as a distinct protected category.
- Technical architecture documentation showing whether biometric matching happens on-device (the user's phone or hardware token) or server-side. This determines your regulatory exposure.
- Legal review capacity to validate the template against your jurisdictions. GDPR treats biometric data as a special category under Article 9; California's CCPA has specific biometric provisions; Illinois' BIPA requires written consent.
- Incident response procedures that you can extend to cover biometric data breaches, which carry different notification obligations than standard Cardholder Data incidents.
If your biometric system stores templates (mathematical representations of biometric features) rather than raw images, document that distinction. It affects your compliance requirements.
The Template
BIOMETRIC AUTHENTICATION POLICY
Payment Systems Division
1. SCOPE AND PURPOSE
This policy governs the collection, processing, storage, and deletion
of biometric identifiers used to authenticate payment transactions.
It applies to all systems where biometric data replaces or supplements
traditional authentication factors (passwords, PINs, security questions).
Biometric identifiers covered:
- Fingerprint templates
- Facial geometry maps
- Voice prints
- Iris scans
- [Add others your systems use]
This policy does not cover photographic images used for identity
verification during account opening (see KYC Policy [reference]).
2. REGULATORY FRAMEWORK
Our biometric authentication practices comply with:
- PCI DSS Requirement 8.3 ([Multi-Factor Authentication](/glossary/multi-factor-authentication) for access
to Cardholder Data Environment)
- GDPR Article 9 (special category data requiring explicit consent)
- [Add jurisdiction-specific: CCPA Section 1798.140(b), Illinois BIPA,
[NIST SP 800-63B](/glossary/nist-sp-800-63b) Section 5.2.3]
3. COLLECTION AND CONSENT
We collect biometric data only when:
- The user explicitly opts in through a documented consent flow
- The consent mechanism explains what biometric data we collect,
how we use it, and how long we retain it
- The user can complete transactions without biometric authentication
(alternative authentication method available)
Consent must be:
- Separate from general terms of service
- Specific to biometric data collection
- Revocable at any time through account settings
Documentation: Retain consent records for [specify retention period
based on jurisdiction, typically 3-7 years after account closure].
4. TECHNICAL CONTROLS
Biometric matching architecture:
[Choose one and delete others]
- ON-DEVICE ONLY: Biometric matching occurs on user's device.
No biometric templates transmitted to or stored on our servers.
- HYBRID: Device captures biometric, creates template, transmits
encrypted template to server for matching against stored reference.
- SERVER-SIDE: Raw biometric data transmitted to server (requires
strongest controls below).
Required controls for any server-side biometric processing:
- Encryption: Biometric templates encrypted at rest using AES-256
with Key Encryption Keys (KEK) managed in hardware security module.
Data Encryption Keys (DEK) rotated [specify: quarterly/annually].
- Transmission: All biometric data transmitted over TLS 1.3 or higher.
[Point-to-Point Encryption (P2PE)](/glossary/point-to-point-encryption-p2pe) required if biometric data shares
network segments with Cardholder Data.
- Access control: [Role-Based Access Control](/glossary/role-based-access-control) (RBAC) limits biometric
template access to [specify roles: authentication service accounts,
[security incident](/glossary/security-incident) responders]. All access logged and reviewed
[specify: weekly/monthly].
- Segmentation: Biometric authentication systems reside in network
segment separate from Cardholder Data Environment. Segmentation
Testing conducted [specify: annually/per PCI DSS assessment cycle].
- Liveness detection: Systems must implement liveness detection
to prevent presentation attacks (photos, masks, recordings).
5. RETENTION AND DELETION
Biometric templates deleted:
- Immediately upon user request
- Within [30/60/90] days of account closure
- Automatically if account inactive for [specify period]
Deletion must be cryptographic (destroy encryption keys) or physical
(overwrite storage) per NIST SP 800-88 media sanitization guidelines.
Audit logs of biometric authentication events retained separately
per PCI DSS Requirement 10 (retain one year, three months online).
6. [BREACH NOTIFICATION](/glossary/breach-notification)
Biometric data breaches trigger notification to:
- Affected users within [specify timeframe per jurisdiction]
- Supervisory authorities per GDPR Article 33 (72 hours)
- Payment card brands if breach affects payment authentication
Notification template: [Reference [incident response plan](/glossary/incident-response-plan) section X]
Biometric breach severity: Treat as CRITICAL given inability to
reissue biometric identifiers. Assume all affected accounts
compromised; force re-enrollment with additional [identity verification](/glossary/identity-verification).
7. VENDOR MANAGEMENT
Third-party biometric authentication providers must:
- Provide SOC 2 Type II report covering biometric data controls
- Contractually commit to this policy's retention and deletion terms
- Notify us of subprocessor changes (GDPR Article 28 requirement)
- Maintain cyber insurance covering biometric [data breach](/glossary/data-breach)
[specify minimum coverage amount]
8. USER RIGHTS
Users may:
- Request copy of their biometric template metadata (not the
template itself, which is not human-readable)
- Revoke biometric authentication and delete templates
- Opt out without penalty (alternative authentication provided)
Response timeframe: [30 days per GDPR Article 12]
9. TRAINING
Staff with biometric system access complete training on:
- This policy
- Biometric data sensitivity and breach implications
- Incident identification and reporting procedures
Training frequency: [Annually, or upon role change]
10. POLICY REVIEW
Review this policy [annually/following any biometric system change/
following regulatory update].
Approved by: [Title]
Effective date: [Date]
Next review: [Date]
How to Customize It
Section 1 (Scope): List only the biometric modalities your systems actually use. Update the policy when you expand capabilities.
Section 2 (Regulatory Framework): Add every jurisdiction where your users reside. If you operate in Texas, Washington, or New York, add their state biometric laws. If you're a payment institution under PSD2, reference Strong Customer Authentication requirements in Article 4.
Section 4 (Technical Controls): The on-device vs. server-side choice fundamentally changes your risk profile. On-device matching eliminates most regulatory burden but limits your fraud analytics. Server-side matching gives you cross-device consistency and fraud detection but requires the full control stack in the template.
If you're using FIDO2 biometric authenticators, note that explicitly. FIDO2's architecture (private key on device, public key on server) provides a middle ground where you verify authentication results without handling biometric data.
Section 5 (Retention): Match your deletion timeframes to the strictest regulation you're subject to. GDPR requires deletion "without undue delay" when consent is withdrawn. Illinois BIPA requires deletion within a "reasonable time." Define "reasonable" based on your technical architecture.
Section 8 (User Rights): If you're subject to GDPR, users have the right to data portability. Biometric templates aren't portable in practice, but document that you'll provide metadata: enrollment date, authentication event count, template version.
Validation Steps
After you've customized the template:
Map to your PCI DSS ROC: Identify which requirements this policy satisfies. At minimum, it supports Requirement 8.3 (MFA), Requirement 3 (data retention and disposal), and Requirement 12.1 (documented security policy). Your QSA should reference this policy in those sections.
Cross-reference your data flow diagrams: Confirm that the technical controls in Section 4 match your actual architecture. If your diagram shows biometric templates crossing a network boundary, your policy must address encryption in transit.
Test your deletion procedures: Before you finalize retention timeframes in Section 5, verify you can actually delete templates in that window. Run a test account through enrollment, authentication, and deletion. Confirm the template is cryptographically unrecoverable.
Validate consent language: Your legal team should confirm that the consent mechanism described in Section 3 meets the "explicit consent" standard under GDPR Article 9(2)(a). Pre-ticked boxes don't qualify. Consent bundled with other terms doesn't qualify.
Review with your acquiring bank or payment processor: If biometric authentication affects your transaction flow, your processor needs to understand your architecture. Some processors have specific requirements for biometric authentication in card-not-present transactions.
Simulate a breach notification: Walk through Section 6 with your incident response team. Identify gaps in your current notification templates. Biometric breaches require different language than Cardholder Data breaches because the harm is permanent.
This policy becomes a living document. When you add a new biometric modality, update Section 1. When a new regulation takes effect, update Section 2. When your architecture changes, update Section 4. Your annual PCI DSS assessment should include a review of this policy's accuracy.
