Complaint to National Human Rights Commission of Korea
Submission date: January 13, 2026
Reception number: 26-진정-0067300
Publication date: January 30, 2026
The National Human Rights Commission of Korea (NHRCK) has consistently sounded the alarm about the risks posed by facial recognition and fingerprinting technologies, dating back to at least 2005. At that time, the Commission condemned the use of fingerprint readers at a university library as a violation of human rights. Therefore, I am requesting that the Commission once again standby its legacy and issue a warning regarding the Korean government's plan to require facial scans to register smartphone SIM cards. Other major human rights organizations have been speaking out against the use of this technology. For example, Amnesty International has been advocating the ban of facial recognition technology in its "Ban the Scan" campaign. Likewise, the ACLU has also been a continual critic of digital IDs and facial recognition. The NHRCK should also make a strong statement against the use of intrusive measures that mandate the collection of biometric information.
10 Reasons Why Facial Recognition Violates Human Rights
1. Smartphones have become essential devices for living in society. They are nearly as important as bank accounts. Without a smartphone, it is close to impossible to obtain employment and live a normal life in society. Biometric identifiers are the unique property of their possessor, and therefore, should be considered in light of the property rights of Article 23 of the Korean Constitution. By forcing citizens to provide their biometric information to register a SIM card for a device that is essential for living in society, the government is depriving citizens of their property rights and failing to provide them compensation for the use of their property.
2. Against the backdrop of SK Telecom's recent data leak and the Korean government's violation of the Personal Information Protection Act in sending over 170 million photos of travelers' faces to a facial recognition company without their consent, there are no guarantees that the facial scans used to register SIM cards will be secure and protected according to law. Biometric identifiers are permanent, and unlike passwords and registration numbers, they cannot be changed if compromised. Even temporary processing of them introduces a risk of misuse and data breach that is irreversible and lifelong.
3. The mandating of facial scans invokes the procedural protections of the Administrative Procedures Act, particularly Articles 5 and 23 which require the administrative agency to be "concrete and clear" with regard to the content of the administrative action (which in this case, due to the high sensitivity of the personal data, should include not only be the purpose and scope of the administrative action, but also the technology and algorithms used in handling the biometric information), as well as the invoking Articles 27 to 39-2 in order to exchange opinions and hold hearings. Despite these provisions, the government failed to collect public opinions and is attempting to push through this measure without public support.
4. The introduction of facial scans nullifies the presumption of innocence. It is the transition from implicit approval to default denial. It would mark a radical change in society that must be confronted and severely scrutinized. Once this type of system is fully integrated into society, it will become extremely difficult to unwind and repeal it.
5. Facial recognition is not an infallible technology. It can produce errors and have a large impact upon the victims of its errors. For example, like any verification technology, it is susceptible to false positives and false negatives. Such errors are bad enough, but when they happen with more frequency among people of a certain skin color or certain facial features, they violate the principles of equality and non-discrimination.
6. Facial scans are being introduced with the goal of reducing crime, but the technology is unproven and comes with serious cybersecurity risks. Korea's e-government infrastructure has suffered numerous cyberattacks over the past few years, and the introduction of facial recognition simply creates a new attack vector. If a government database of images is hacked, the damage to individual citizens would be enormous.
7. The introduction of facial scans creates the potential for "mission creep," where an initial objective gradually changes to achieve more expansive objectives. We have seen this in China, and more recently Vietnam, where digital ID and biometric verification suddenly became a requirement for verifying bank accounts in 2025, and now in 2026 are scheduled to be required for riding public transportation. Biometric verification could easily become normalized in society as people become accustomed to having their face scanned and fingerprints read, similar to how people became accustomed to having their body temperature measured and contact information recorded during the COVID measures of 2020-2022.
8. The government says that facial data used in SIM registration is not stored, but this is not true. At the very least, the scanned facial images are stored in RAM, and then cross checked against the facial images on national ID cards and driver's licenses stored in permanent memory on a government server. There are security concerns for this type of real-time processing, such as unauthorized access from man-in-the-middle attacks. There is also the potential for the government's PASS application to be exploited and compromised, giving the hacker access to both the RAM and the permanent memory location, as well as sensitive metadata. (If, instead, physical ID cards and driver's licenses are scanned and cross checked with facial scans, then this would effectively nullify the purpose of this administrative measure. A criminal could simply create a fake ID with his photo on it and obtain a SIM card under a fake name.)
9. The introduction of facial scans subjects citizens to a humiliation ritual. Facial images are typically associated with mug shots of people under arrest for an alleged crimes. Forcing citizens to be face scanned to prove their identity is humiliating and an attack on human dignity. Even worse, the people most subjected to this humiliation will most likely be young people who are trying to register their first phone number.
10. There have already been over 50,000 people who have petitioned the Korean National Assembly to ban facial scans, indicating that a large number of people understand that this measure would be a violation of human rights.
Thank you for taking the time to read this. I look forward to receiving your response.
Links:
https://banthescan.amnesty.org/
https://www.aclu.org/issues/privacy-technology/national-id
https://www.aclu.org/issues/privacy-technology/surveillance-technologies
https://petitions.assembly.go.kr/proceed/onGoingAll/3F25B381AE2A24B3E064ECE7A7064E8B
