Diritto & Internet

Graphometrics signature on tablets: a recent decision by the Italian D.P.A.

A recent decision by the Italian Data Protection Authority authorizes the use of the graphometric signature on tablets in the banking sector.

The system, which has been submitted for preliminary examination by the Italian D.P.A., is somewhat complex, split into different phases and involves a number of different parties.

The technology used is also able to detect the characteristics of a customer’s signature online by means of an analysis of certain criteria which can be deduced from the signature, such as the speed of the stroke, its pressure, acceleration, inclination and so on.

The system is intended to be used by financial promoters for customer authentication and for subsequent operations. There are two main phases in the process: firstly the collection of the specimen signature to be used as a tool for comparison in order to safeguard the customer, and secondly the signing of documents with the electronic signature.

As set out in the decision, the specimen signature together with the customer’s identification data is transmitted by the bank through secure encrypted channels to the certifier, who validates the request and issues the digital certificate associated to the applicant. All subsequent signings will thus be transmitted in encrypted mode to the certifier’s server which verifies the correspondence by means of the specimen signature and ensures that the tablet serial number is in fact listed.

This system would allow a reduction in the risk of cases of fraud, in particular those related to identity theft.

As usual the Authority draws attention to the adoption of special measures in order to protect personal data. With particular regard to the use of mobile devices, the D.P.A. recommends that the processing of biometric user data should be carried out adopting all appropriate security measures in order to reduce to a minimum the risk of unauthorised software installation or to avoid contact with malware.

According to the D.P.A. remote wiping must also be adopted, which would guarantee that in cases where tablets have been tampered with, lost or stolen, their content would be deleted remotely.

Moreover, processing of biometric data is subject to customer consent. The D.P.A. underlines the importance that consent, where required, must be free and responsible.

Finally, The D.P.A. draws attention to the need to ensure that biometric data is not preserved for a duration exceeding the purposes for which it was collected and subsequently processed. Any extension to the retention time may be justified by specific laws.

Further requirements under existing law are reaffirmed including notification of process and obligation to designate external parties as data processors.

Giusella Finocchiaro

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Scientific Director
Prof. Avv. Giusella Finocchiaro
Editorial Curator
Dott. Giulia Giapponesi