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FAQ 16

16. Is a photo a Biometric?

A biometric is "A measurable physical characteristic or personal behavioural trait used to recognise the identity of an enrolee or verify a claimed identity."
You could also say: Bio -> life -> (living) individual or group Metric -> measure -> comparable for establishing identity of "biometric" refers to a characteristic that satisfies the two.
Face is then a biometric. Scars or tattoos can be if they are able to do the above. The same biometric can be in many forms - photographs, digital images.
It can also be transformed from raw -> features -> templates.
Provided the photograph has been captured in line with ISO 19794-5 then it is "a measurable physical characteristic" of a person, ergo it is.
But if it is a photograph of a house, a sillhouette of a person, a photograph of multiple people - then it would not pass the ISO 19794-5 tests, so it would not be.
Given that ISO-compliant hardcopy photos (and sometimes ones that aren't) can be scanned and uploaded to generate templates that work with facial matching systems, you'd have to say in that sense a photograph also is a biometric.
By our ISO 19794-5 definition, for the photo to be a biometric, there is an intent that the photo is captured for biometric matching purposes and QA checked against standards as part of that process, against a neutral background.   So we'd argue that a passport style photo of a person taken at random at home would not be a biometric because it was not taken for biometric measurement purposes.
A biometric is any biological attribute that can be used for identification - hence strictly a photo qualifies, as does in fact a picture or video of any part of the body. However just because a selection of photos exists of employees for instance (ICAO compliant or not) this does not mean there is the capability or intention to do anything biometric with the photos.
In other words they could be called 'latent' biometrics - similar to a latent fingerprint that is left on a surface but that may not be used. Any clear photo of a person contains some biometric information - but if there is no intention to convert it to a template or match it against a facial gallery then I would say it is open to debate as to its status as a biometric in the technical or legal sense.
It's the purpose that counts. A driver licence authority that has photos stored for the purpose of identification (biometric) might be different from a human resources use or facebook style application ('latent' biometrics). For instance consider video libraries and TV stations or newspapers, they might be considered vast biometric repositories if any photo of a human qualified as a biometric. Obviously purpose can change - and so what was a 'latent' biometric might become an actual biometric with a change of usage.

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