In contrast, we have considerable reservations about the use of biometric data for identification purposes (1:n comparison), which is inevitably associated with central storage of the data. Such processing of sensitive data is permissible if the purpose limitation and access rights to this data are regulated in sufficient detail in a legal basis in the formal sense (ID card law). Indeed, only a rigid legal framework can limit the risks of misuse and excesses as well as the danger of using the biometric data as access keys to various databases and thus linking different data sets. In our opinion, the amendment to the ID card law proposed in the above-mentioned federal resolution does not meet the conditions mentioned here. For this reason, we did not support the retention of biometric data in the ISA and ISR files for identification purposes.
Source: FDPIC – Introduction of biometric data in identity cards