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Statement on Facial Recognition technology in relation to Personal Identifiable Information in Fotoware’s solutions

Fotoware permits the use of Facial Recognition technology in our solutions in relation to Personal Identifiable Information of either public figures or individual persons where they have given explicit consent beforehand. * 

The legal and ethical concerns surrounding the use of Facial Recognition (FR) technology for individuals require every vendor to assume greater responsibility and to be explicit on what use is acceptable. 

With Fotoware’s open API it is possible for customers to connect their system to third-party FR tools. Should a customer choose to integrate technology with FR functionality through our open API for Facial Recognition purposes on individuals that are not defined as public individuals, it is contingent upon explicit, prior written consent given by the individual. The purpose of the usage must be clearly stated and defined so that the individual can make an informed decision regarding their consent.  

In-house training of facial recognition technology on individuals that have given explicit consent to their data being used for training purposes, either via consent form or in the case of an employee-employer relationship, via work contract, can be applicable for Facial Recognition in Fotoware’s solutions.   

*The use of Facial Recognition technology in connection with public individuals will still apply, such as, but not limited to, international or local celebrities, TV-stars, influencers, YouTube personalities, reality TV participants, sports figures and athletes, international and local professional singers and musicians, government officials, public officials, politicians, writers, company representatives, prominent business leaders, people involved in public affairs, limited or all-purpose public.


The advancement of artificial intelligence and machine learning technologies in recent years has driven a remarkable increase in efficiency, reliability, and innovation across a wide range of areas. The Digital Asset Management industry has been no exception, with technology enabling improvements such as automatic metadata tagging, speech-to-text conversion, image recognition and more.  

There are many instances in which the application of artificial intelligence and machine learning technology demonstrates significant benefits and utility, while at the same time adhering to accepted standards, ethics, and regulations.  

Many data processing regulations worldwide, including the GDPR (EU and UK), consider biometric data as ‘Special Category Data’ and ‘Sensitive Personal Data’, which means the processing of such data requires a greater than ordinary level of care.  

There are five main concerns associated with facial recognition technology, which involve bias and discrimination, privacy, security, lack of training data, and risk of errors. The combination of these factors has led to several major players such as Microsoft, Amazon and IBM implementing thorough and manual vetting routines for the usage of such technology on their platforms. Furthermore, facial recognition for individuals is considered to be highly invasive of privacy and private life, challenging basic rights and freedoms, and conflicting with data processing regulations, including the EU’s legal framework and the Charter of Fundamental Rights.  

For Fotoware, personal privacy, security, and protection against bias and discrimination are high priorities. These topics will continue to be part of our decision-making process on matters such as Facial Recognition technologies and other product development discussions which could affect individual persons and abovementioned priorities. Fotoware will never use, support or develop technologies that are unethical, illegal or wrongful. 

Personal Identifiable Information (PII) is defined as:  

Any representation of information that permits the identity of an individual to whom the information applies to be inferred by either direct or indirect means. This includes biometric data, such as photos and videos of a person’s face, among other physical, physiological, or behavioral characteristics.  

Further questions

For further questions or clarifications about this topic, you can contact us at info@fotoware.com