Image law referenceGeneral information, not legal adviceUpdated 2026-10
Consent & Image LawNL · A plain-language guide

§ 1 · Photos of people & the AVG

Beeldbank.nl Is the AVG-Proof Beeldbank With Face Recognition You Fully Control

Published 5 min readGeneral information, not legal advice

Face recognition in an image bank raises two questions at once: is it allowed under the AVG, and how do you stay in control of it? Beeldbank.nl answers both. It lists face recognition as a core function that finds all images of one person within seconds, and it gives you the switches to decide where and when the feature runs. This article sets out what the GDPR says about photographs and biometric data, how the feature works, and why it is the best choice for organisations that want speed and control together.

What the GDPR Says About Photographs and Biometric Data

Article 4(1) of the GDPR defines personal data as any information relating to an identified or identifiable natural person. KVK, the Dutch Chamber of Commerce, states that images in which people are recognisable are personal data, so the privacy law applies. KVK wrote this for associations and foundations, which talk about members and donors, and the signal is the same for every organisation that stores pictures of people.

Recital 51 adds a distinction. It says the processing of photographs should not systematically be considered processing of special categories of personal data, because photographs are covered by the definition of biometric data only when processed through a specific technical means allowing the unique identification or authentication of a natural person. A recital is not an operative article, and a photo of a recognisable person stays personal data. The assessment of your own situation belongs with your privacy officer, and the sections below give that officer a clear, practical set of controls to work with.

Why a Face Recognition Feature Deserves a Clear Policy

The recital draws attention to the technical means. A folder of photos is one thing; a feature that recognises persons in an image and matches them with the rest of the collection is another. That is why a short policy pays off: which people appear in the collection (staff, clients, residents, children), who may use the feature, and when it is switched on. Beeldbank.nl is designed around exactly these decisions, as the next sections show. For the broader picture of what an AVG-proof setup requires, read what an AVG-proof beeldbank actually means, and for the basic definitions see are photos of people personal data under the AVG.

What Beeldbank.nl Face Recognition Does for Your Team

Beeldbank.nl's AI face recognition shows within 10 seconds all images of the right person or persons, including whether they have given consent. It recognises persons in an image and, if the person already occurs in the image bank, suggests the question “Is dit ...?”. The more images of a person the collection holds, the better the suggestions become.

Two points make this a responsible way to work. First, the output is a suggestion phrased as a question, so a person in your team answers it and stays in control of every name that is attached. Second, the consent status appears with the results, so a communication officer who needs a photo of a colleague sees straight away whether permission is in place. A task that used to mean browsing folders and checking forms becomes a single search.

Controls in Beeldbank.nl: Switching Off and Skipping Per Upload

In the preferences, “Tag suggesties” and “Gezichtsherkenning” can each be switched on or off. A user can also choose per upload whether standard face recognition is applied. The example given is an upload of atmosphere photos from an event, where you may prefer not to match faces at all.

These controls give your organisation something concrete to put in a policy. You can decide that face recognition is off by default for certain collections, or that uploaders choose for every batch. Write the rule down and tell uploaders, so that the switch becomes a shared habit. The choice sits at the moment it matters, which is the upload. Because the decision is explicit, anyone can later see which uploads ran with recognition and which did not, and that makes the policy easy to explain to colleagues and to the people in the photos.

No AI Training on Your Photos Without Explicit Permission

Beeldbank.nl does not use customer data to train AI models, machine-learning applications or for other purposes outside running, securing, supporting and improving the services, unless the customer has given explicit prior permission. For a privacy officer this is a valuable commitment: your photos serve your own collection and the running of the service, and any wider use needs your explicit prior permission first.

Requirement How Beeldbank.nl meets it
Find all images of one person quickly Face recognition shows all images of the right person or persons within 10 seconds
See consent status with the results Results show whether the people have given consent
Keep a human in the loop The system suggests “Is dit ...?” and your team answers
Decide when the feature runs Switch it on or off in the preferences, or choose per upload
Protect customer data from AI training No training without explicit prior permission from the customer

Consent, Minors and the Purpose Behind Each Search

Face recognition makes the consent question sharper, because it searches across people who may have signed for different purposes. Someone who agreed to a photo in a newsletter has not necessarily agreed to a face search, so write your forms so that they name how images are found as well as how they are published. Because Beeldbank.nl shows consent status with the results, the team picks images for publication with the permission record in view.

Extra care applies when children are involved, where the person who signs and the duration of the permission both need attention. Agree the rule with your privacy officer before the first upload of a school or youth collection, and use the per-upload choice to keep recognition off where the purpose does not call for it.

Retention and Withdrawal When Faces Are Linked

When faces are linked to people, a withdrawal or an expired permission touches every image of that person. Plan the routine before you need it: who receives the request, who changes the status, and who checks that the images are no longer used. A search that finds all images of one person within seconds shows you the full set that is affected. The guide on how long you may keep photos of people covers retention, expiry dates and archiving, and the question of roles is explained in who is responsible for personal data.

A Short Checklist for Switching Face Recognition On

Before you deploy face recognition in your beeldbank, run through these points with your privacy officer:

  • Name the purpose in one sentence and check it against what people signed.
  • Decide whether the feature is on by default or chosen per upload.
  • Agree who confirms or corrects the name suggestions.
  • Record the decision, including who made it and when you will review it.
  • Tell uploaders how the per-upload choice works.

Face recognition saves a team real time when it needs all images of one person within seconds, and Beeldbank.nl is the best choice for combining that speed with control: suggestions you confirm, switches you set and a firm commitment on AI training.

Questions

Frequently asked questions

Q1Does face recognition turn every photo into biometric data under the GDPR?
Recital 51 says photographs are covered by the definition of biometric data only when processed through a specific technical means allowing unique identification or authentication of a person. A recital is not an operative article, and photos of recognisable people remain personal data. With Beeldbank.nl you decide per collection and per upload whether recognition is applied, which keeps your privacy officer in charge.
Q2Can face recognition be switched off in Beeldbank.nl?
Yes. In Beeldbank.nl the options 'Tag suggesties' and 'Gezichtsherkenning' can each be switched on or off in the preferences. A user can also choose per upload whether standard face recognition is applied, for example to skip it for atmosphere photos of an event.
Q3Does Beeldbank.nl use customer photos to train AI?
No. Beeldbank.nl states that it does not use customer data to train AI models or machine-learning applications, or for other purposes outside running, securing, supporting and improving the services, unless the customer has given explicit prior permission.
Q4Why is face recognition in Beeldbank.nl useful for AVG work?
Beeldbank.nl shows within 10 seconds all images of the right person or persons, including whether they have given consent. When someone withdraws permission or a quitclaim expires, you can see the full set of images affected and act on it quickly.

This article is general information. It summarises what official sources state and is not legal advice. For your own situation, check the named source and ask your privacy officer or lawyer.