The National Data Protection Authority (ANPD) of Brazil has taken decisive action against Tools for Humanity (TFH), ordering the company to suspend the provision of cryptocurrency or any financial compensation in exchange for iris data collection. 

The precautionary measure is set to take effect on January 25, 2025. Additionally, the ANPD has mandated that TFH disclose on its website the responsible party for processing personal data.

This decision follows an inspection initiated by the ANPD's General Coordination of Inspection (CGF) in November 2024. 

The investigation aimed to evaluate the processing of biometric data by TFH, specifically for its World ID initiative. According to the company, the World ID is designed to authenticate individuals as unique, living human beings, enhancing digital security in an era of expanding artificial intelligence technologies.‍

Concerns Over Consent and Vulnerability

The CGF's analysis raised concerns about the company's approach to obtaining consent from individuals. Under Brazil's General Data Protection Law (LGPD), consent for processing sensitive personal data, such as biometric information, must be freely given, well-informed, unequivocal, and specific to a defined purpose. 

The CGF found that offering monetary compensation, including cryptocurrency, could compromise individuals' ability to provide truly voluntary consent, particularly among vulnerable populations.

“The monetary incentives may unduly influence individuals’ decisions to provide their biometric data,” the CGF noted, emphasizing the potential impact on those in financially precarious situations. This influence, they argued, undermines the principle of free expression of will required for valid consent under the LGPD.‍

Irreversible Data Concerns

Further concerns were raised about the serious implications of processing sensitive biometric data. The CGF highlighted the challenges posed by the irreversibility of biometric data collection and the inability to delete such data once it has been gathered. These factors, combined with the irreversible nature of revoking consent, prompted the ANPD to impose the preventive measure against TFH.