Provision record
Revolut · Revolut Privacy Policy (Superseded URL) · View original document ↗

Special Category and Biometric Data Processing

Medium severity Medium confidence Explicit document language Common · 287 of 352 platforms
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Document Record

What it is

Revolut collects copies of your identity documents and processes biometric-style data as part of identity verification, which is a more sensitive category of personal data under UK data protection law.

ⓘ

This analysis describes what Revolut's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

Identity document data and biometric verification data are treated as special categories under UK GDPR, meaning stricter rules apply to how they are collected, stored, and used, and Revolut must have a stronger legal basis for this processing.

⚠

Interpretive note: The document does not specify retention periods for identity documents or the precise legal basis for biometric-style processing, creating interpretive uncertainty about whether all UK GDPR special category requirements are fully addressed in disclosed terms.

Consumer impact (what this means for users)

Revolut retains copies of your passport or driving licence and processes them through identity verification systems, which constitutes high-sensitivity data processing; if there were a data breach involving this data, the consequences for affected individuals could be severe.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    Email dpo@revolut.com to ask what identity document data Revolut holds about you, how long it is retained, and to request deletion where legally permissible. Note that AML regulations may require retention for a statutory minimum period.

How other platforms handle this

Duolingo Medium

Request that we limit our use of your sensitive personal information to what is necessary to perform the services you requested.

Public.com Medium

Objection to Processing. You have the right to object to us processing your personal data, where the legal basis for processing that information is legitimate interest.

Binance.US Medium

Right to data portability. You have the right to request that we transfer the information that we have collected to another organization, or directly to you, under certain conditions.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
copies of your identification documents (for example, your passport or driving licence) and any other information you provide to prove you are eligible to use our services

Excerpt from Revolut's Privacy Policy (Superseded URL)

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: Processing of biometric data used for unique identification and identity document data may engage UK GDPR special category provisions, requiring an explicit legal basis such as explicit consent or a legal obligation …

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

Applicable regulations

Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FCRA
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
GLBA
United States Federal
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Revolut Privacy Policy (Superseded URL)
Entity
Revolut
Date stated by the document
March 17, 2026
As printed in Revolut’s text (version CA-V-001210), not a ConductAtlas date.
Tracking information
First captured by ConductAtlas
May 5, 2026
Text quoted from version
CA-V-001210, captured May 5, 2026
Record ID
CA-P-007674
Document ID
CA-D-000538
Evidence Provenance
Source URL
Wayback Machine
Extracted-text SHA-256 (version CA-V-001210)
1da1030466936879b98258377878e6f17ddb321522079e8c401a642a5d3459b8
Analysis generated
May 7, 2026 09:22 UTC
Methodology
Evidence
✓ Excerpt found verbatim in version CA-V-001210 (checked Oct. 5, 2026)
Citation Record
Entity: Revolut
Document: Revolut Privacy Policy (Superseded URL)
Record ID: CA-P-007674
Version: CA-V-001210
Captured: 2026-05-05 05:58:14 UTC
SHA-256: 1da1030466936879…
URL: https://conductatlas.com/platform/revolut/revolut-privacy-policy-superseded-url/provision/CA-P-007674/special-category-and-biometric-data-processing/
Accessed: Oct. 10, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does Revolut's Special Category and Biometric Data Processing clause do?

Identity document data and biometric verification data are treated as special categories under UK GDPR, meaning stricter rules apply to how they are collected, stored, and used, and Revolut must have a stronger legal basis for this processing.

How does this clause affect you?

Revolut retains copies of your passport or driving licence and processes them through identity verification systems, which constitutes high-sensitivity data processing; if there were a data breach involving this data, the consequences for affected individuals could be severe.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 287 platforms. See the full comparison.

Is ConductAtlas affiliated with Revolut?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Revolut.