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Revolut · Revolut Privacy Policy (Superseded URL) · View original document ↗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 · 290 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.

Clause Stability Stable

0
Changes
3
Months Monitored
May 9, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 5148 other provisions on other platforms.

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

Square Medium

to request that your data be transferred to a third party (data portability)

Google Cloud Medium

Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.

Roblox Medium

Further, you may take legal actions in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data prot...

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
Document last updated
May 5, 2026
Tracking information
First tracked
May 7, 2026
Last verified
May 9, 2026
Record ID
CA-P-007674
Document ID
CA-D-00538
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
3f454e91dd6036e21544d2d7f616cb24e6b62cdc91bd14ac3626b944cdb7ec1f
Analysis generated
May 7, 2026 09:22 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Revolut
Document: Revolut Privacy Policy (Superseded URL)
Record ID: CA-P-007674
Captured: 2026-05-07 09:22:24 UTC
SHA-256: 3f454e91dd6036e2…
URL: https://conductatlas.com/platform/revolut/revolut-privacy-policy-superseded-url/provision/CA-P-007674/special-category-and-biometric-data-processing/
Accessed: Aug. 26, 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 290 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.