O’Brien Legal insights

AI governance, biometrics & facial recognition

Legal and governance analysis for New Zealand organisations using AI, biometric processing and facial-recognition technologies.

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New Zealand’s New Legal Code for Biometric Processing: What Businesses Need to Know

The Biometric Processing Privacy Code 2025 is now law under the Privacy Act. It introduces a specific and enforceable set of rules for any organisation in New Zealand using biometric technologies such as facial recognition, voice ID, fingerprints, or similar tools to identify, verify, or categorise individuals.Key Dates • The Code comes into force on 3 November 2025 • Organisations already using biometric systems must comply by 3 August 2026 This Code substitutes the 13 standard privacy princi