UK GDPR places restrictions on the processing of sensitive data known as Special
Category Data. We will process Special Category data such as biometric, nationality and
genetic data under Article 9 of UK GDPR. Biometric and nationality data is processed
under UK GDPR Article 9 (2) (g) - substantial public interest. Where customers have
decided to voluntarily submit evidence of genetic relationships in support of an application
it will be processed with the explicit consent of all parties under Article 9 (2) (a) consent.
In addition, we use personal information we hold for a number of other purposes:
• Customer Research: Customers may be contacted about the services we offer
and to get customer opinion about how such services should be run in the future.
You may be contacted by customer research companies appointed by HM Passport
Office to carry out surveys on our behalf.
• Training and Assurance: We use personal information when training our staff –
primarily when training those conducting interviews or dealing with customers over
the telephone. We will review personal information as a necessary part of
conducting audits to ensure that our staff are carrying out their duties effectively and
in accordance with the law.
• Testing our systems: We prefer to use “dummy” or anonymised data for testing
our IT systems but exceptionally, we use some personal information to assist in
testing our systems effectively where no other reasonable alternative exists. In such
circumstances, we ensure that the security and integrity of personal data is never
put at risk.
• Statistical analysis: In order to review the effectiveness of our services, we will
collate information to measure and judge our performance. Wherever possible, we
will use anonymised data to achieve this but some personal information may be
involved in conducting such analysis where no reasonable alternative exists.
• Customer Service Messaging: In some cases, we will send customers a text,
email or letter acknowledging receipt of an application, confirming successful
completion of an application or to confirm an appointment, when customers have
provided us with a mobile telephone number or email address. We will also attempt
to send a text, email or letter to remind customers when their passport is reaching
the end of its validity.
• Images in Publications and Projects: Data subjects that volunteer or give
permission to HM Passport Office to use their photographs in publications or
projects will be asked for consent to use their image. Consent is provided under
Article 6 (1) (a) of the UK General Data Protection Regulation and data subjects can
withdraw consent at any time.
Detecting and preventing crime.
• The data provided in applications is also used to identify fraud patterns and develop
fraud risk indicators.
• Passport photographs submitted with passport applications may be compared
against other passport photographs to prevent and detect identity fraud and may be
shared with other agencies to fulfil their aims and objectives where there is a legal
gateway to do so.
• Passport photographs submitted with passport applications may be compared
against facial images from law enforcement agencies in order to prevent or detect