Multimodal Handheld Biometric Identification

Unlike single-modality handheld facial recognition, which checks a photographed face against one watchlist, multimodal devices combine several biometric and identity checks in a single unit: a face, a fingerprint, a scanned document and sometimes a vehicle plate, all checked in the same street stop against multiple databases at once.

THE GREEK CASE

The fullest documented example is Greece's Smart Policing programme, which equipped Hellenic Police officers with 1,000 devices.

Officers capture biometric data during an on-the-spot check and compare it instantly against national, EU and international databases including the Schengen Information System, the Visa Information System, EURODAC, and systems linked to Europol and third-country authorities. Human Rights Watch and Homo Digitalis reported comparison against roughly twenty databases including Interpol. Police stated that biometric data processed during stops would not be retained and would be used solely for instantaneous comparison before being discarded.

The contract was signed with Intracom Telecom in spring 2019, valued at €4 million, with 75% funded by the European Commission's Internal Security Fund. The state paid in full and the devices were delivered fully functional.

THE RULING

After Homo Digitalis brought the programme to light with AlgorithmWatch in December 2019, filed an access-to-documents request, received an inadequate response and lodged a formal complaint in March 2020, the Hellenic Data Protection Authority ruled the procurement, operation and use of the Smart Policing system unlawful in Decision 45/2025, dated 31 December 2025.

An earlier June 2020 ruling had already established that the CCTV law the ministry relied on did not cover facial recognition or comparable identification methods.

This is a regulator finding an EU-funded, fully procured and delivered biometric system unlawful after the money was spent.

WHY THIS MATTERS BEYOND GREECE

Set against two other entries on this site, it completes a picture. In Italy, the data protection authority blocked a real-time facial recognition system before deployment. In the United Kingdom, handheld operator-initiated facial recognition proceeds with no dedicated statutory framework and a consultation response long overdue. In Greece, a system was fully built and paid for before being found unlawful.

Three jurisdictions, one broad capability, three entirely different regulatory outcomes — determined by when the regulator engaged rather than by anything about the technology.

THE CASE FOR IT

Establishing identity in the field is a legitimate function, and a device resolving it in seconds is faster than the alternative of detention for identification.

Multimodal checking is also more reliable than face alone: where a facial match is inconclusive, a fingerprint resolves it, reducing one category of error.

The stated non-retention position — instantaneous comparison then discard — is a narrower proposition than systems that build databases from field encounters.

THE CASE AGAINST

The gallery is the fundamental issue. Checking a person against SIS II, VIS and EURODAC is not a policing watchlist check; it is a check against EU immigration and border infrastructure, and the programme was reported as targeted at stops of undocumented migrants living in the country. That places it in immigration enforcement conducted through ordinary street policing.

The procurement sequence is the governance failure. €4 million of largely EU money was spent, and a thousand devices delivered, before the lawfulness question was resolved — and it was resolved only because a civil society organisation pursued it for five years.

Non-retention is a stated policy, not a technical guarantee, and no independent verification of it was identified.

WHAT IS NOT ESTABLISHED

Current operational status following the ruling is unclear; this site records the programme as discontinued pending confirmation.

Whether the devices were withdrawn, repurposed or destroyed is not established.

Whether the European Commission sought recovery of Internal Security Fund money spent on a system later ruled unlawful is not documented.

How many stops were conducted using the devices before the ruling is not published.