Milan Linate Airport Facial Recognition System Declared Unlawful for GDPR Violations
Italian data protection authorities declared the FaceBoarding facial recognition system at Milan Linate Airport unlawful for GDPR violations. The system retained biometric data centrally without passenger consent, failed to encrypt templates, and captured facial images from non-consenting passengers using hybrid gates.
What happened
The Italian data protection authority (Garante della Privacy) declared the FaceBoarding facial recognition system at Milan Linate Airport unlawful on 15 April 2026, following a preliminary suspension order issued in September 2025.
Sea operated FaceBoarding to allow passengers to access secure areas and boarding gates by registering at kiosks or via app, with facial images matched to identification documents and boarding passes.
The authority found that Sea retained all acquired biometric data centrally on its own servers, preventing passengers from exercising exclusive control over their data, and did not encrypt the biometric templates.
Reported impact
Sea conserved biometric templates for up to 12 months, creating significant risk of personal data breaches.
The system acquired facial images without consent from passengers using hybrid gates who had not opted into FaceBoarding.
Index analysis
The authority determined that FaceBoarding violated the GDPR and contradicted guidance from the European Data Protection Board on facial recognition in airport settings.
Sea distributed inaccurate information to passengers about the system.
Classification
Sources and evidence
This record was researched and written by the Index, based on the following original reporting.