How to ensure GDPR compliance when implementing passkeys?

To comply with GDPR while implementing passkeys, organizations must focus on data protection, transparency, and privacy by design. Passkeys, being a privacy-centric technology, align well with GDPR requirements when used appropriately.

1. Data Minimization:

   • Only process the minimum data required for passkey functionality. For example:
     • Temporary use of email addresses for passkey creation.
     • Avoid permanent storage of Personally Identifiable Information (PII).
   • Some passkey solutions process data transiently and link passkeys to non-PII identifiers like user UUIDs.

2. Transparency and Consent:

   • Clearly inform users about what data is processed and why.
   • Obtain explicit consent if PII is temporarily processed during passkey registration or login.
   • Update privacy policies to reflect passkey-related data handling practices.

3. Data Security Measures:

   • Encrypt all data in transit and ensure secure storage of cryptographic keys.
   • Regularly conduct privacy impact assessments (PIAs) to evaluate compliance risks.

4. Vendor and Third-Party Compliance: If outsourcing passkey implementation, ensure that vendors adhere to GDPR through contractual agreements and third-party assessments.

5. Audit and Documentation:

   • Maintain detailed records of data processing activities related to passkeys.
   • Implement audit trails to monitor access and modifications to passkey-related data.

By following these practices, organizations can ensure that passkey implementations meet GDPR standards, protecting user data while enhancing security and user experience.