Unadhi · Australia & New Zealand

NZ Biometric Processing Privacy Code 2025: compliance checklist for organisations

The Biometric Processing Privacy Code 2025 (made under the Privacy Act 2020) applied from 3 November 2025 to new biometric processing. For processing already running before then, the transition period ended on 3 August 2026, so the code now applies to everyone using face, voice, fingerprint or similar recognition.

Checklist

  1. List every biometric system (access control, facial recognition, voice ID, identity checks).
  2. Record why it's necessary, and the lower-privacy alternatives you considered (rule 1).
  3. Check your notices and signage.
  4. Record retention periods and accuracy testing.
  5. Keep this record dated and reviewable.

Sources: OPC: Biometric Processing Privacy Code · NZ Gazette notice

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