[Verse 1]
Madrid desk, November third, ink still wet,
AEPD drops an opinion, not a mandate yet,
One financial firm, asking "can we scan the face
for one-to-one checks" when new customers show their place,
Answer comes back: ex ante — that's Latin, "before the fact" —
it might clear necessity, proportionality intact,
even though, on record, a softer road exists,
they let the firm proceed, but check the fine print, read the list.
[Chorus]
Не вирок, це лиш думка — non-binding, hear me say,
One firm, one question, doesn't pave a general way,
Це не дозвіл, this ain't a license set in stone,
Read between the headline, know what's left alone.
[Verse 2]
Left out the margin: this ain't a stamp, ain't a seal,
no general green light, just one private deal,
workplace clocking, fingerprint punch at the door,
still sits outside this ruling, still the same old law,
back in twenty-three, AEPD drew a harder line —
said if a safer option's there, biometrics cross that line,
this new opinion drifts from that November creed,
different question, different firm, a narrower need.
[Verse 3]
Now the plot thickens, like a palimpsest rewrit,
old guide scraped at the edges, but the ink still legit —
Audiencia Nacional, June thirtieth, the gavel fell,
Sentencia three sixty-seven, procedural as well,
they didn't touch the substance, just the paperwork, the trail,
so the twenty-three stance on workplace scans could still prevail,
meanwhile Yoti's nine hundred fifty thousand euro fine
stays suspended, under appeal, still drawing the line.
[Verse 4]
What's coming next? No date carved for this one call,
but the access-control draft closed September, in the fall,
no final version's surfaced, still waiting on the shelf,
Digital Omnibus's just a proposal, by itself,
AVPA's nervous — a stricter reading might chip the EUDI Wallet's base,
AEPD's still warning: error rates run high
for women, darker skin, when the cameras misidentify.
[Verse 5]
Compliance teams take note, the lesson's clear and plain,
context matters most, don't treat each case the same,
ask the real question first, necessity and scope,
before you scan a face, check if there's another hope,
a single yes for one request still leaves the door ajar,
for every other use case, you're still left to go far,
so don't mistake one ruling for a blanket of consent,
each biometric ask still needs its own assessment.
[Chorus]
Не вирок, це лиш думка — non-binding, hear me say,
One firm, one question, doesn't pave a general way,
Це не дозвіл, this ain't a license set in stone,
Read between the headline, know what's left alone.
[Bridge]
Watch the ruling, watch the vote, watch the final draft arrive,
Дивимось, чекаємо — we keep the story live,
appeal, the Omnibus, the guide still in the queue,
November tenth update, now the fuller picture's true.
[Outro]
Non-binding, one firm, read the fine print twice,
Чекаємо далі — that's the compliance advice.