Possible privacy violation in Spanish football stadiums ahead

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Spanish football stadiums

MADRID – The Spanish Data Protection Institute, AEPD, has warned the La Liga football league about the possible unlawful processing of personal data in its football stadiums.

The warning comes after a tender procedure was initiated for the development of a facial recognition system. La Liga would like to use the system to provide supporters with access to the stadiums.

Legal requirements

With the warning, the AEPD states that such a system must comply with data protection law. Furthermore, the institute points out that La Liga’s plans give rise to a preliminary investigation and corrective measures, including sanctions, if the legal requirements are not met.

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The introduction of any technology that processes biometric data requires prior actions. These are necessary to ensure and demonstrate that the processing of such data is following the law.

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Important criteria

If there is a ‘high risk’, a facial recognition system may be justified. However, according to the Privacy Regulation, this requires an impact assessment. This must meet three legal criteria: suitability, necessity, and proportionality.

The data protection institute has urged La Liga to review whether it meets the legal requirements of the data protection law. The regulations expressly prohibit the processing of data revealing racial or ethnic origin, political opinions, or religious beliefs.

The processing of genetic, biometric, or health data or data about a person’s life or sexual orientation is also not simply permitted.


Although citizens are protected by law when it comes to privacy-sensitive information, there are some exceptions which the law may be deviated from. If a data subject gives clear consent or when there are necessary reasons for the public interest, the processing of personal data may be justified.

The AEPD has proposed that Spain’s top football league use a less invasive system to achieve its goals. Furthermore, the institute points out the need to find out whether a facial recognition system is justified, should La Liga actually want to implement the system.


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