VietnamLaw on Personal Data Protection, biometric and location data protection
Law No. 91/2025/QH15, Article 31
In force since .
A biometric privacy rule binding public and private bodies.
- Audit expectation
- continuous
- Who audits it
- Self
What it requires
- An app that collects or processes biometric data, meaning physical attributes and unique, stable biological characteristics used to identify a person, from an individual in Vietnam must apply physical security measures, limit access, and maintain a monitoring system to detect infringement, and must notify the data subject where its processing damages that person.
These lines are LexLint's reading of the law's text.
In the frameworks
Our reading of where this law's duties sit in each framework. It never says that running a control meets the law. How we read a framework against the law
Who enforces it
Settledness
- As of
- Open questions
- Does "dữ liệu về thuộc tính vật lý, đặc điểm sinh học cá biệt và ổn định của một người để xác định người đó" ("data on the physical attributes and the unique and stable biological characteristics of a person, used to identify that person") in Article 31(2) cover a faceprint, voiceprint or fingerprint template derived from a photo or recording, when the Article gives no example of biometric data?
What it makes you log
Logging duty
Article 31(4)(a) requires a party that collects and processes biometric data to restrict access to it and to keep a monitoring system that prevents and detects infringement of that data. The text names no log or record, but a system that detects infringement works from a record of who reached the data and when. The monitoring is a standing duty with no cadence and no outside reviewer, so the party is its own checker. No retention period, regulator access or scope clause appears in the Article. The location-data paragraph in Article 31(3) and the notice to a harmed data subject in Article 31(4)(b) are not record duties.
- Kind
- Implicit
- As of
- Provision
- Article 31(4)(a)
- Trigger
- personal_data_processing
What this law does
Article 31 defines biometric data as data on physical attributes and unique and stable biological characteristics of a person used to identify that person. It requires an organization, agency, or individual collecting or processing biometric data to apply physical security measures for storage and transmission devices, limit access, maintain a monitoring system to detect infringement, and comply with relevant laws and international standards.
Where the processing damages the data subject, the collecting and processing party must notify that data subject as the Government prescribes. Article 31 names no facial, voice, or fingerprint example, resting entirely on the general physical-attribute language; whether the definition reaches an identifier derived from a photo, video, or audio recording is unresolved.
This provision functions as heightened, category-wide protection rather than a named consent-at-capture rule distinct from the Law's general Article 9 consent duty.
When LexLint raises it
When your app profile says your app processes biometric data or processes personal data.
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