Biometric fingerprint readers ditched for hygiene reasons... to be replaced by contactless biometric systems?

On Twitter schools have been spotted ditching biometric fingerprint readers for contactless cards due to hygiene reasons, which completely makes sense as this was one of the issues raised initially over 15 years ago when fingerprint scanners started appearing in schools.  

Though some biometric suppliers have been keen to stress that sterilising fingers before using biometric scanners is good to keep children 'safe'.

So as good as it is to see fingerprint scanners be replaced by less personally intrusive methods it does open the way for a contactless biometric system, i.e. facial recognition, to replace the touch fingerprint pad.

Which seems to be, somewhat, what has happened here at a UTC school in Leeds, UK, where Years 10 (14/15 year old) and Year 12 (17/18 years old) students have started school after having been shut since mid March 2020.  

A combined facial recognition and thermal imaging system has been installed to check student's temperature to identify each student whose temperature is taken.  However it has to be said they have ditched their fingerprint scanners for contactless cards, which was used for building entry, class registration and lunch payment.  The newly installed facial recognition has not directly replaced, on first glances, the fingerprint system but it is still registering the students with their biometric data.

We have also installed a high spec thermal camera in the reception area. This camera uses facial recognition technology to enable unobtrusive thermal imaging and temperature measurements of students and staff. An alert is issued to the Principal if someone’s temperature is above a certain level.

Every school in England and Wales that wishes to process an under 18 year old's biometric data, including facial recognition, needs explicit written parental consent to do so and it is uncertain whether this particular UTC has done that.  When questioned specifically on whether they had gained parental consent, as per the Protection of Freedoms Act 2012, the UTC replied:

Albeit it this is a reply on Twitter (which now looks to be unavailable) but it is not glaringly obvious that the school is operating this biometric system in line with UK legislation specifically aimed at schools processing children's biometric data - The Protection of Freedoms Act 2012.  

The use of facial recognition in UK schools is also questionable under GDPR, the EU General Data Protection Regulations 2018.  Schools in France have been advised not to use facial recognition and a school in Sweden was fined for using the technology.  GDPR does not change at country borders or whether we are Brexiting so the use of facial recognition technology is certainly questionable in this UK school.

There are good reasons legislations are specifically put in place to protect children biometric data being unnecessarily processed and they should be adhered to.