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Facial recognition in residential buildings: what the law requires

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The short answer

LGPD (Brazil's data protection law) treats the face as sensitive personal data. A residential building (condominium) that adopts facial recognition is the controller and needs a legal basis, a clear purpose, notice, security, a retention period and disposal, plus another way in for those who don't want to use their face. The ANPD, Brazil's data protection authority, is still preparing a specific rule for biometrics.

Published on November 10, 2026 · 5-minute read · By ARX Protocol

7:10 p.m., at the front desk. The assembly approved it last week: the key fob goes, the face comes in. Today a resident stops the building manager in the lobby and asks: “What if I don't want to register mine?” It is a fair question. And the law has something to say about it.

This text is general information, written for those who manage a residential building. It is not legal advice.

What does LGPD say about the face?

The General Data Protection Law (Law No. 13,709/2018) calls biometric data linked to a person, among others, sensitive personal data (art. 5, II). A face used to open a door is exactly that.

Sensitive data may be processed only in two situations (art. 11):

  • With consent from the data subject, given “in a specific and prominent way”, for specific purposes.
  • Without consent, when the processing is indispensable for one of the cases set out in the law. One of them is “ensuring fraud prevention and the security of the data subject, in the processes of identification and authentication of registration in electronic systems”.

Which of the two applies to the front desk? The law doesn't say. Some argue for consent and others for the second case. As of the date of this text, we have found no guidance from the ANPD, the federal agency that enforces LGPD, that settles the question. On either path, the principles of art. 6 apply: a clear purpose and use of the minimum necessary.

The building is responsible for the data

The controller, under the law, is the one who makes the decisions about the processing (art. 5, VI). When the building decides to use the face, that role is theirs. The company that supplies the system or runs the front desk is the operator: it processes the data on behalf of the building (art. 5, VII). Both can be called on to repair damage (art. 42).

Two points often go unnoticed:

  • The assembly approves the purchase. It does not replace consent, which under the law is an expression of the data subject themself (art. 5, XII).
  • The ANPD has lighter rules for small-scale agents, and they cover entities without legal personality, which is how a condominium is usually classified. The use of sensitive data, however, is one of the criteria that can rule out this simplification (Resolution CD/ANPD No. 2/2022).

Those who don't want to use their face need another way in

No article of LGPD says, in so many words, “offer an alternative”. The requirement comes from three points in the law:

  • Consent must be freely given. If the face is the only way to get into your own home, there is no choice.
  • The data subject has the right to know that they can say no and what happens if they do (art. 18, VIII).
  • Processing must be limited to the minimum necessary (art. 6, III).

In 2026, when analyzing facial recognition in public schools in Paraná, the ANPD's technical staff wrote that, where a less invasive means exists for the same purpose, biometrics may be considered excessive. The case is different, but it shows how the agency looks at the subject.

In practice: a tag, card, PIN or app, working as well as the face and without embarrassment.

Notice, retention, disposal and care with children and visitors

Notice. Residents have the right to clear information about the purpose, form and duration of the processing, who the controller is and with whom the data is shared (art. 9). A sign at the front desk can't cover all of that. Hand over a simple document before registration.

Retention. The law requires technical and administrative security measures (art. 46). A password can be changed; a face cannot. In 2025, an ANPD director pointed out that this type of data is not like a document, for which you can get a replacement copy.

Disposal. Once the purpose has ended, the data is deleted (arts. 15 and 16). A resident who moved out, an employee who left, a contract that ended: the record is removed from all the equipment and the server.

Children. Processing must be done in their best interest, and the law calls for specific and prominent consent from one of the parents or the guardian (art. 14).

Visitors. Someone who comes in once doesn't need to have their face stored. An ID document, the resident's authorization or a temporary code serve the same function with less data.

What has the ANPD already published?

  • June 2024. The Technology Radar No. 2 study cites access control in buildings and residential complexes among the uses of biometrics and points to risks such as misidentification, discrimination and leaks. It is a study, not a rule.
  • 2025. The agency opened a call for input to regulate the subject and received 88 contributions, compiled in Technical Note No. 23/2025. Some participants criticized facial recognition where simpler means would do, and mentioned gyms and condominiums. It is the opinion of those who contributed, not the ANPD's position.
  • August 2026. The ANPD ordered, in a preventive measure open to appeal, the suspension of facial recognition used to record student attendance in Paraná's public school system.

As of the date of this text, we have not found a specific rule on biometrics in condominiums. The subject is on the agency's regulatory agenda for 2025 and 2026.

What the building manager should require from the vendor

  1. A contract that says who is the controller and who is the operator, and that prohibits using the data for any other purpose.
  2. Where the faces are stored: on the device, on a server in the building or in the cloud.
  3. Whether the system stores the photo or only the mathematical model of the face, and whether the record is encrypted.
  4. An access alternative planned from the design stage.
  5. How a record is deleted, and proof that it was removed from all the equipment.
  6. What happens to the whole database when the contract ends.
  7. Who accesses the records, with individual user accounts and a log of every access.
  8. How and when the vendor notifies the condominium if there is a security incident.
  9. Notice and consent form templates for residents, employees and those responsible for children.

Before rolling this out, take these points to the building's lawyer. If you would like to talk about the access project, with the face and the alternative designed together, ARX is available.

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