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Thuringian Higher Regional Court Rules Biometric Exam Proctoring Without Free Consent Unlawful Under GDPR

The University of Erfurt was ordered to pay €200 over its use of Wiseflow, signaling stricter limits on surveillance in digital exams.

Overview

  • The higher court held that processing biometric data for face recognition during online exams violates GDPR when consent is not truly voluntary.
  • The ruling arises from University of Erfurt’s 2020 remote exams, where students had to submit reference photos and undergo ongoing identity checks.
  • The court found students lacked a real choice to refuse, and it said pandemic-related interests did not require biometric processing that intrudes on informational self-determination.
  • The case focused on Wiseflow, which performed face recognition and forwarded biometric data to Amazon Web Services, a practice the court deemed unlawful.
  • The decision in second instance overturns a 2024 lower-court dismissal, grants the plaintiff €200 in damages, and is viewed by GFF as a signal for universities and potential workplace surveillance.