Employee photos and data protection: What HR needs to consider under the Swiss FADP

A portrait photo directly identifies a person. This makes it personal data, and processing it requires a defined purpose, a limited duration, and a sound contractual basis.

Purpose limitation

A photo collected for the access card is therefore not automatically approved for the intranet, the website, or a marketing brochure. If you want both, obtain both — and document them separately.

Retention

After export to the target system, the photo platform has no reason to keep the image. Deletion should therefore not be planned as a clean-up task, but as a fixed step at the end of the process.

Data processors

If capture is outsourced, a controller–processor relationship is created. At a minimum, the following must be clarified: Where are the servers located? Who has administrative access? Are subcontractors used? How long does deletion take after export?

A practical note on AI

Whether and how a face is altered is a separate question. A system that replaces the background and sets the crop does not alter the face. A generative system would — and for an identity document, that would be unacceptable.

This article provides context and does not replace legal advice.