← Cases
SpainManufacturing2022–2023

Albero Forte Composite (Plastic Forte)

Facial recognition for employee attendance

A Spanish court ordered Plastic Forte to cease unlawful facial attendance processing and compensate a worker

StoppedRegulator, audit or court

Problem

Plastic Forte used facial recognition to record employees' working hours. The manufacturer argued that attendance recording was a legal obligation.

Approach

By March 2022, the company used facial images for clocking employees in and out through purchased attendance software. The court found that a worker had not consented to that purpose, had not been offered an alternative, and that the company lacked the required data protection impact assessment. The company paid a reduced €12,000 regulatory penalty in February 2023; in September, the court ordered cessation of the unlawful conduct and €6,251 in compensation. Plastic Forte announced an appeal and disputed descriptions of the system as surveillance, saying it served attendance recording.

Results

€12,000reduced regulatory penalty paidRegulator, audit or court[1]
€6,251compensation ordered for the workerRegulator, audit or court[1]

Takeaway

The obligation to record working hours did not resolve the separate requirements attached to facial identification. The company had obtained permission for promotional images, which the court found did not cover attendance processing.

Categories

Innovation type
Process innovation
AI technology
Computer vision
Evidence
Regulator, audit or court

Sources

  1. Sentencia Social 190/2023 Juzgado de lo Social de Alicante/Alacant nº 2, Rec. 489/2023 de 15 de septiembre del 2023
    Juzgado de lo Social de Alicante/Alacant nº 2, reproduced by Iberley15 Sep 2023Regulator, audit or court document

Source summaries

[1]Juzgado de lo Social de Alicante/Alacant nº 2, reproduced by Iberley15 Sep 2023

The judgment established use of facial attendance processing in March 2022 and recorded payment of a €12,000 regulatory penalty. It found a violation of the worker's privacy and image rights, ordered cessation of the conduct, and awarded €6,251 in compensation.

[2]elDiario.es26 Apr 2023

The report identified Plastic Forte as a plastics manufacturer with about 470 employees. It described the company's attendance-recording explanation and reported that acknowledgment of responsibility and early payment reduced the proposed €20,000 penalty to €12,000.

[3]elDiario.es25 Sep 2023

The report described the compensation ruling and the company's announced appeal. A published company correction disputed the characterization of attendance recording as surveillance and said the regulatory penalty concerned a missing technical requirement rather than failure to inform employees.

Full details are in the original sources.

Added 4 Nov 2026 · Updated 4 Nov 2026
Open case page ↗