Asian Journal of Criminal Justice and Forensic Studies

The aim of this study was to compare Kazakhstani and Chinese models of privacy and security in biometric systems. The research established that Kazakhstan and China represent two different approaches to biometric identification: the former is a balanced model between state control and international standards, while the latter is a utilitarian model in which state security is prioritised. The study applied theoretical analysis to conceptually distinguish key terms and identify threats; a comparative-legal analysis of the legislation of Kazakhstan and China; and the case-study method to examine high-profile incidents of data leaks and political surveillance. The research found that China implements a utilitarian model of total control (via the “Xueliang” project), whereas Kazakhstan – despite its declared balanced/transitional model with a focus on forensics – de facto exhibits weak law enforcement and a tendency towards data leaks. This is evidenced by an explosive 101.7% rise in cyber incidents in the first quarter of 2025, which renders the country vulnerable to threats of authoritarian surveillance. It was demonstrated that in both jurisdictions the absence of genuine voluntariness of consent and the opacity of biometric application are key privacy risks. A number of practical recommendations were formulated for Kazakhstan, including strengthening enforcement (introducing independent cybersecurity audits) and enshrining the principle of proportionality in law to restrict mass facial recognition. The results are important for shaping effective legal mechanisms in transitional states to protect civil liberties. Accordingly, the findings may be considered by countries at the stage of implementing biometric technologies to better understand potential risks and challenges

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