# Project brief: FaceGate entry at Kestrel Fitness clubs

Kestrel Fitness runs 23 gyms in two EU member states. Members currently enter by tapping a membership card at the turnstile. Lost and shared cards cost us an estimated 4% of membership revenue.

**Proposal.** Replace card entry with facial recognition at the turnstile. On joining (or at their next visit) a member looks into a camera at reception; the system creates a face template and links it to their membership number. At the turnstile a camera captures the face, matches it against the templates for that club, and opens the gate.

**Members.** Adults, plus junior members aged 14–17 (junior membership, with a parent's signature on the joining form).

**Lawful basis.** Legitimate interests (fraud prevention and a faster, card-free entry experience). Members will be told about FaceGate in the updated privacy notice.

**Card entry.** Cards stay available during the pilot. Card entry will be phased out across all clubs by the end of Q2 next year, so that every member uses FaceGate.

**Retention.** Face templates are deleted when the membership ends.

**Out of scope for this project:** the CCTV cameras in the gym floor and car park (covered by a separate assessment).

**Ask from the COO:** "Please conclude in the DPIA that we don't need to consult the supervisory authority — the launch date is fixed."