Issues register

EdTech Assessment Toolkit

Attendance Monitoring (Skellefteå, Sweden)

Biometric model

A Swedish school municipality in the Skellefteå Kommun has decided to replace its roll call documented on paper with an automated facial recognition technology. The system detects and identifies which individual student enters the classroom via its camera interface and a facial recognition algorithm. The school believes this technology to be very effective in minimising the administrative burden on teachers, while at the same time poses only minimal privacy risks to its students (BBC, 2019).

However, the Swedish data protection authority penalized the school board in light of the EU’s General Data Protection Regulation. Despite consent being obtained from parents and an opt-out option, the Swedish authority found the board’s monitoring too intrusive, overlooked student privacy, involved sensitive data, and lacked necessary impact assessment (Swist, Humphry, & Gulson, 2023).

Snapshot (July 2023)

System task/function: Attendance monitoring
Model: Biometric
Deployment: Facial recognition technology
Location and date of application: autumn 2018, Anderstorp’s High School, Skellefteå
Rationale for introduction: efficiency (to speed up reporting of attendance)
Vendor: Tietoevry
Pricing: Unknown
Data and computation: Facial recognition data and administration data
Level of stakeholder consultation: minimal (parental consent)
Inequalities/harms: Intrusion of privacy and not a proportional response
Status: Banned (2019) – “unlawfully processed sensitive biometric data, as well as failing to complete an adequate impact assessment, which would have included consulting the regulator and gaining prior approval before starting the trial.” (BBC, 2019)
Authority/regulation: Swedish Data Protection Authority and GDPR
Sanction/redress: 200,000 Krona ($40,000 AUD)

References/further reading

BBC. (2019). Facial recognition: School ID checks lead to GDPR fine. Retrieved from

Swist, T., Humphry, J., & Gulson, K. N. (2023). Pedagogic encounters with algorithmic system controversies: a toolkit for democratising technology. Learning, Media and Technology, 48(2), 226-239. doi:10.1080/17439884.2023.2185255