Reclaim Your Face impact in 2021

A sturdy coalition, research reports, investigations, coordination actions and gathering amazing political support at national and EU level. This was 2021 for the Reclaim Your Face coalition – a year that, despite happening in a pandemic – showed what the power of a united front looks like.


Forming a coalition in a strategic moment

In January 2021, a group of civil society organisations were meeting every 2 weeks to strategise and plan what has become one of the most politically–powerful campaigns: Reclaim Your Face.

Set on a mission from October 2020, the coalition of then 12 organisations came together to form the Reclaim Your Face coalition, aiming to ban biometric mass surveillance in Europe. Since then we welcomed dozens more organisations, which work on digital rights and civil liberties, workers’ rights, the rights of Roma and Sinti people, LGBTQ+ rights, media freedom and the protection of migrants and people on the move. We gathered activists, volunteers, technologists, lawyers, academics, policy-makers – all united in one common goal.

The launch of the campaign happened at a strategic moment when the EU began its work on a law proposal to regulate artificial intelligence (AI). The relevance and timing of the Reclaim Your Face campaign is unquestionable as AI techniques are at the centre of today’s biometric surveillance technologies such as facial recognition.

Raising awareness of the spread and harms of biometric mass surveillance

For the people in the Reclaim Your Face coalition, 2021 started with a strong focus on raising awareness about the harms associated with biometric mass surveillance. More, we showed this exploitative practice is a reality in many cities across Europe and not a dystopian fiction story.

Check out our video records.

Researching biometric mass surveillance

EDRi’s Brussels office and the leading organisations of the campaign coordinated research: mapping both technology deployments and legal frameworks that govern (or not) biometric mass surveillance practice in some EU countries.

Coordinating pandemic-proof actions

In 2021, we also coordinated online and offline actions that enabled every campaign supporter to act as part of a powerful collective. The pandemic put constraints on realising such actions, however, the creative hive mind behind the campaign made it happen!

The #PaperBagSociety stunt sparked curiosity and started discussions among curious minds as Reclaim Your Face activists wore paper bags on their heads in public spaces as a sign of protest. The #WalkTheTalk Twitter storm united activists across the Atlantic in calling on the EU Commissioner Vestager and the US Secretary Raimondo to not negotiate our rights in their trade discussions.

Politically, our success has been clear

Our European Citizens Initiative has been positioned as “perhaps the most politically powerful” of all to date. Thank you to the almost 65,000 EU citizens who have supported it so far!

Firstly, together we successfully set the agenda of the debate on AI. Not only were the words “ban” and “remote biometric identification” (a prominent technique that leads to biometric mass surveillance) included in the AI Act law proposal, but many EU and national affairs newspapers acknowledged the importance of the topic and reported heavily on it.

Secondly, we gathered support from several influential bodies that also called for a ban: EU’s top data protection regulators (the EDPS and EDPB), the Green Group in the EU Parliament, as well as Germany’s newly elected government, several national data protection authorities and UN officials. Our impact is also evident in the report Members of the EU Parliament adopted, calling for a ban on biometric mass surveillance by law enforcement.

Through our coalition, we successfully applied pressure on national governments that tried to sneak in laws that enabled biometric mass surveillance in Serbia and Portugal.  In Italy, Reclaim Your Face campaigners helped to catalyse a moratorium on facial recognition, and in Hamburg, data protection authorities agreed with us that the use of EU citizens’ face images by ClearviewAI is illegal.

Moving ahead in 2022, the Reclaim Your Face coalition is aiming to expand its reach, bringing together even more organisations fighting against biometric mass surveillance. We will train the many volunteers who have offered their support and reach a new level of political engagement.

Thank you for supporting us!

No biometric surveillance for Italian students during exams

In September 2021 the Italian Data Protection Authority (DPA) fined Luigi Bocconi University €200 000 for using Respondus, a proctoring software, without sufficiently informing students of the processing of their personal data and, among other violations, for processing their biometric data without a legal basis. Bocconi is a private University based in Milan and during the COVID-19 pandemic introduced Respondus tools to monitor students during remote exams. 


Respondus offers two different modules: Lockdown browser and Respondus Monitor. The former prevents a student from using their computer as usual, meaning that the person for example cannot open other programs. Respondus Monitor checks that the person in front of the screen is the one that should be taking the exam, in order to prevent someone else from replacing the student or passing notes. To do this, the software uses algorithms that analyse the biometric data of the person’s face in order to confirm their presence and it also records keystrokes, mouse movements and the duration of the exam. After processing the data, the software sends the professor a report showing the student’s image for identification purposes and alerts of any anomalies, with details on the reason for the alert. 

The University initially tried to walk back from what they stated in their own privacy policy, claiming that no biometric data was processed given that the only identification happening was the one concerning the initial picture taken by the software and used by an operator (in this case the professor) to confirm the identity of the student. Something that didn’t match the real functioning of the system. In fact, in their decision, the DPA says that Respondus declared that their software creates a biometric template to monitor the presence of the same person in front of the screen throughout the exam. For this reason, the “software performs a specific technical processing of a physical characteristic of the persons,” says the DPA and, currently, in Italy there is no legal provision expressly authorising the processing of biometric data for the purposes of verifying the regularity of exams. The DPA highlights also that, considering that the processing was carried out by the University for the purpose of issuing degrees with legal value and the specific imbalance in the position of students with respect to the University, consent does not constitute the legal basis of the processing nor can it be considered as freely given. 

In addition, the DPA considers the functionalities of the ‘Respondus Monitor’ component as a “partially automated processing operation for the analysis of the behaviour of the data subjects, in relation to the subsequent assessment by the teacher,” and this “gives rise to the ‘profiling’ of the students.”

This processing of personal data, according to the DPA, may have an impact on the emotional and psychological sphere of the persons concerned which “may also derive from the specific functionalities of the supervision system, such as, in this case, facial recognition and behavioural profiling, with possible repercussions on the accuracy of the anomalies detected by the algorithm and therefore, indirectly, also on the overall outcome of the test.” 

Laptop and book, both open

Bocconi is not the only Italian University using proctoring software. In June 2020 in Italy there were at least ten Universities using (or planning to use) similar tools such as Proctorio, ProctorExam, and Safe Exam Browser. This Authority’s decision would prohibit other Italian Universities from using software similar to Respondus that collect and process students’ biometric data.

Despite this push back on student monitoring, this decision also reminds us that biometric surveillance is increasingly expanding into every sphere of our lives and the only solution is to call for a ban on these technologies.

Contribution by: Laura Carrer, Research and Advocacy at Digital Rights Unit, Hermes Center & Riccardo Coluccini, Reclaim Your Face national campaign contributor.