Facing facts: The state of US and EU facial recognition legislation - Covington ...
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Facing facts: The state of US and
ANALYSIS
EU facial recognition legislation
F
By sam choi, hannah Lepow, christopher Lin, and Jadzia Pierce of Covington &
Burling LLP.
acial recognition technology on law enforcement agencies’ use of Representatives, yvette Clarke (D-Ny)
(FRT) is being developed and any biometric surveillance system in in July 2019 and introduced in the
deployed at phenomenal speeds connection with police-worn body- Senate by Sen. Booker (D-NJ) in Octo-
and lawmakers worldwide are scram- cams.3 ber 2019—would regulate the use of
bling to catch up. The resulting pieces In March 2020, Washington state FRT by landlords who receive some
of legislative and enforcement efforts enacted a bill that prescribes several form of federal financial assistance.12
convey that although there is consensus requirements for agency use of FRT.4 Similarly, a House bill proposed by
that something needs to be done to reg- Among other things, prior to deploy- Rep. Rashida Tlaib (D-MI) would pro-
ulate the burgeoning technology, there ing the technology, agencies will be hibit any federal funding from being
is little consensus on the approach that required to file a notice of intent and used for the purchase or use of FRT.13
should be taken. In this article, we publish an accountability report that We are aware of one federal pro-
highlight some of the key trends that will be subject to public review and posal that would broadly regulate com-
have come out of the United States and comment. Use of FRT to make deci- mercial use of FRT, without a federal
the European Union thus far. sions that produce legal or “similarly funding hook. The Commercial Facial
significant” effects (e.g., decisions per- Recognition Privacy Act, introduced
rkfqba pq^qbp taining to financial services, housing, just over a year ago in March 2019 by
In the United States, legislative propos- criminal justice, or employment oppor- Sen. Roy Blunt (R-MO), would pro-
als can be divided into those seeking to tunities) will be subject to heightened hibit commercial entities from, among
regulate government use of FRT and requirements. In addition, certain uses other things, collecting facial recogni-
those seeking to regulate commercial will be substantially limited, including tion data from end users without affir-
use of FRT. the use of FRT for ongoing surveil- mative consent.14 The bill has not pro-
dçîÉêåãÉåí=ìëÉ=çÑ=coq: Propos- lance, real-time or near-real-time iden- gressed since its initial referral to
als aimed at regulating government use tification, or persistent tracking with- committee.
of FRT run the gamut from imposing out a warrant (or in other limited There are active bills seeking to reg-
complete moratoriums on such use to circumstances). ulate commercial use of FRT in nearly a
creating specific requirements and various states are considering their dozen states, from California15 and
guidelines that agencies would be own pieces of legislation that regulate New Jersey16 to Idaho17 and Ala-
required to follow. government use of FRT in a variety of bama.18 The majority of these follow
In February 2020, Sens. Jeff ways, such as Arizona,5 Massachusetts,6 the formula of the broadest federal pro-
Merkley (D-OR) and Cory Booker New Hampshire,7and vermont.8 In posal, prohibiting the use of FRT with-
(D-NJ) introduced the Ethical Use of addition, multiple city governments out some type of notice provided to
Facial Recognition Act, which would have taken matters into their own and/or consent obtained from the con-
prohibit any federal agency official hands — the cities of San Francisco,9 sumer. However, certain of the bills
from using FRT without a warrant Oakland,10 and Somerville,11 for exam- focus on specific issues. For example,
until Congress enacts legislation imple- ple, have ordinances in place that the Maryland state legislature recently
menting guidelines for such use.1 As largely ban city officials’ use of FRT for passed a bill prohibiting the use of FRT
another example, in November 2019, surveillance. during job interviews without the
Sens. Chris Coons (D-DE) and Mike `çããÉêÅá~ä= ìëÉ= çÑ= coqW= Federal applicant’s consent.19 Additionally, one
Lee (R-UT) introduced the Facial and state proposals aimed at regulating New york proposal would prohibit
Recognition Technology Warrant Act commercial use of FRT range from landlords from using FRT in residential
of 2019, which would prohibit using cross-sector regulation to bills that properties.20 While none of the federal
FRT for ongoing surveillance in a focus on a particular contexts, such as proposals discussed above include an
public space unless such surveillance is housing or employment. express private right of action, several
in support of a law enforcement activ- The majority of the federal propos- state bills do.21
ity and certain other conditions are als addressing commercial use of FRT
met.2 from this Congressional session are brolmb^k rkflk
State legislatures, meanwhile, have limited to spheres in which the federal In the EU, the General Data Protection
moved past legislative proposals and government has some authority, such Regulation (GDPR), and its law
actually enacted legislation. In October as through funding. For example, the enforcement counterpart, the Police
2019, California enacted A.B. 1215, No Biometric Barriers to Housing and Criminal Justice Directive, apply
which creates a three-year moratorium Act—introduced in the House by to commercial and government use of
OO ======= ^mofi=OMOM= ==============PRIVACY LAWS & BUSINESS INTERNATIONAL REPORT © 2020 PRIVACY LAWS & BUSINESS
ANALYSIS
FRT. Facial images are deemed per- use. For instance, the Danish DPA White Paper on AI,29 setting out the
sonal data under the GDPR, meaning approved in July 2019 Brøndby Foot- EU’s vision for building an “ecosystem
that controllers of FRT systems must ball Stadium’s use of FRT to enforce a of trust” regarding AI use in the EU
comply with certain obligations — ban list for security purposes.25 DPAs through a robust legislative framework.
including transparency, processing data are continuing to investigate other uses Among other things, the White Paper
fairly and securely, and complying with of FRT, such as at London King’s Cross proposes a mandatory pre-marketing
individuals’ requests to exercise rights development and by Clearview AI. 26 conformity assessment requirement for
they have over their personal data. In the UK, use of FRT systems was high-risk AI applications. The Commis-
Where facial images are used for the challenged from a human rights law sion recognizes “remote biometric iden-
purpose of uniquely identifying indi- perspective at the UK High Court.27 tification systems” — such as FRT use in
viduals they constitute “special cate- The European Convention on Human public spaces — as an example of a high-
gory personal data,” and are subject to Rights provides that everyone “has the risk AI application that could be subject
heightened obligations under the right to respect for his private and to this conformity assessment require-
GDPR (Art. 9). In those circumstances, family life, his home and his correspon- ment. In the White paper, the Commis-
the controller may need to obtain dence.” (Art. 8.) With a few exceptions, sion notes that FRT systems are already
explicit consent from individuals public authorities may not interfere heavily regulated under existing EU laws
whose faces are processed by the FRT with the exercise of this right. The (as described above), but that there are
system, or alternatively, identify a sub- complainant alleged that South Wales unique concerns raised by their deploy-
stantial public interest for the process- Police Force’s use of FRT for policing ment in public spaces. The Commission
ing under EU or Member State law. and security purposes infringed this further states that it will “launch a broad
In the last few years, FRT systems fundamental human right, as well as European debate on the specific circum-
have been deployed in a range of differ- UK data protection laws and equality stances, if any, which might justify such
ent settings in Europe. Accordingly, a legislation. The court found in favor of use, and on common safeguards.”30
number of data protection authorities South Wales Police Force’s use of FRT
(DPAs) in different Member States based on the specific facts of the case. `lk`irpflk
have examined FRT use within the Nonetheless, this case prompted the Although FRT has become a popular
construct of the GDPR.22 Notably, the UK Information Commissioner to topic among lawmakers, it is unclear
European Data Protection Board, investigate and issue an opinion on whether varying legislative and
made up of representatives from DPAs police use of FRT, calling on the UK enforcement efforts may someday con-
in each Member State and formally government to introduce a statutory verge into a unified approach. What is
established to issue GDPR guidance, binding code of practice on the use of clear is that lawmakers’ activities never-
has issued guidance on FRT use.23 In biometric technology, such as live facial theless may influence the technology’s
some cases, DPAs have found that cer- recognition technology.28 continued development and use. As a
tain uses of FRT systems are in breach Further regulation of FRT, particu- result, it will be critical to continue to
of the GDPR. For example, on larly by public authorities, remains an track key developments and be
21 August 2019, Sweden’s DPA fined open issue in the EU. Although the prepared to adapt, as needed.
the Skellefteå municipality for using GDPR offers safeguards for individuals
FRT to track student attendance in a whose facial images are processed by
public school, concluding that: (1) FRT systems, some policymakers and AuthoRs
tracking attendance with FRT was commentators think that these meas-
Sam Choi, Hannah Lepow and Jadzia
overly invasive, (2) the imbalance of ures do not go far enough to protect Pierce are Associates, and Christopher
power between the students (the data fundamental human rights. This debate Lin is a Legal Intern, at Covington &
subjects) and the school (the data con- over the need for further FRT regula- Burling LLP in the US.
troller) invalidated student consent, tion has arisen at the EU level in the Emails: jchoi@cov.com
hlepow@cov.com
and (3) the school did not conduct a context of future regulation of AI tech-
jpierce@cov.com
data protection impact assessment.24 In nologies. On 19 February 2020, the clin@cov.com
other cases, DPAs have permitted FRT European Commission published a
RefeRences
1 S. 3284, 116th Cong. (2020), available leginfo.legislature.ca.gov/faces/billPdf.x use-of-facial-recognition/
at html?bill_id=201920200AB1215&versio 5 S.B. 1383, 54th Leg., 2d Reg. Sess.
www.congress.gov/116/bills/s3284/BILL n=20190AB121593CHP (Ariz. 2020), available at
S-116s3284is.pdf 4 Alex Berengaut & Jadzia Pierce, www.azleg.gov/legtext/54leg/2R/bills/S
2 S. 2878, 116th Cong. (2019), available InsidePrivacy.com, Washington State B1383P.pdf
at Passes Bill Limiting Government Use of 6 S. 1385, 91st Gen. Ct. (Mass. 2019),
www.congress.gov/116/bills/s2878/BILL Facial Recognition (Mar. 23, 2020), available at
S-116s2878is.pdf www.insideprivacy.com/united- malegislature.gov/Bills/191/S1385.pdf
3 A.B. 1215, 2019–2020 Leg., Reg. Sess. states/state-legislatures/washington- 7 H.B. 1642, 2020 Leg. (N.H. 2020),
(Cal. 2019), available at state-passes-bill-limiting-government- available at
© 2020 PRIVACY LAWS & BUSINESS PRIVACY LAWS & BUSINESS INTERNATIONAL REPORT ^mofi=OMOM OP
ANALYSIS/NEWS
RefeRences
gencourt.state.nh.us/bill_status/billText. egislation/H0492/ 2019), edpb.europa.eu/news/national-
aspx?id=1202&txtFormat=html&sy=202 18 H.B. 295, 2020 Leg., Reg. Sess. (Ala. news/2019/facial-recognition-school-
0 2020), available at renders-swedens-first-gdpr-fine_en;
8 H. 923 (Vt. 2020), available at legiscan.com/AL/text/HB295/id/214360 Sofia Evardsen, International
legislature.vermont.gov/bill/status/2020/ 9/Alabama-2020-HB295-Introduced.pdf Association of Privacy Professionals,
H.929 19 H.B. 1202, 2020 Leg., 441st Sess. (Md. How to Interpret Sweden’s First GDPR
9 City of San Francisco, Cal., Stop Secret 2020), available at Fine on Facial Recognition in School
Surveillance Ordinance, available at mgaleg.maryland.gov/2020RS/bills/hb/ (Aug. 27, 2019), iapp.org/news/a/how-
sfgov.legistar.com/LegislationDetail.asp hb1202T.pdf to-interpret-swedens-first-gdpr-fine-on-
x?ID=3850006&GUID=12FC5DF6- 20 S. 5687, 2019–2020 Leg., Reg. Sess. facial-recognition-in-school
AAC9-4F4E-8553-8F0CD0EBD3F6 (N.Y. 2019), available at 25 European Digital Rights, Danish DPA
10 City of Oakland, Cal., Surveillance www.nysenate.gov/legislation/bills/2019 Approves Automated Facial
Equipment Ordinance Amendment, /s5687 Recognition (June 19, 2019),
available at 21 See West Virginia, H.B. 4106, 2020 https://edri.org/danish-dpa-approves-
oakland.legistar.com/LegislationDetail.a Reg. Sess. (W.V. 2020), available at automated-facial-recognition.
spx?ID=3976661&GUID=CB1D4794- www.wvlegislature.gov/Bill_Text_HTML 26 Meera Narendra, Data Protection World
7549-485A-A345-B7B38B38E191 /2020_SESSIONS/RS/bills/HB4106%2 Forum, #Privacy: Swedish DPA
11 City of Somerville, Mass., Face 0INTR.pdf; Hawaii, S.B. 3148, 30th Announces Investigation Into the Use of
Surveillance Full Ban Ordinance, Leg. (Hawaii 2020), available at Clearview AI (Mar. 9, 2020),
available at egiscan.com/HI/text/SB3148/id/213516 gdpr.report/news/2020/03/09/privacy-
somervillecityma.iqm2.com/Citizens/De 3/Hawaii-2020-SB3148-Amended.html; swedish-dpa-announces-investigation-
tail_LegiFile.aspx?Frame=&MeetingID= Maryland, H.B. 307, 2020 Leg., 441st into-the-use-of-clearview-ai; Information
2961&MediaPosition=&ID=20991&Css Sess. (Md. 2020), available at Commissioner’s Office, Statement: Live
Class legiscan.com/MD/text/HB307/id/217169 Facial Recognition Technology in King’s
12 H.R. 4008, 116th Cong. (2019), 6/Maryland-2020-HB307- Cross (Aug. 15, 2019),
available at Engrossed.pdf; New York, S. 1203, ico.org.uk/about-the-ico/news-and-
www.congress.gov/116/bills/hr4008/BIL 2019–2020 Leg., Reg. Sess. (N.Y. events/news-and-blogs/2019/08/
LS-116hr4008ih.pdf; S. 2689, 116th 2019), available at statement-live-facial-recognition-
Cong. (2019), available at legislation.nysenate.gov/pdf/bills/2019/ technology-in-kings-cross.
https://www.congress.gov/116/bills/s26 S1203 27 R. (Bridges) v. Chief Constable of South
89/BILLS-116s2689is.pdf 22 See, e.g., Kristof Van Quathem & Anna Wales Police, [2019] WLR (D) 496
13 H.R. 3875, 116th Cong. (2019), Oberschelp de Meneses, (U.K.).
available at InsidePrivacy.com, French Supervisory 28 Sam Jungyun Choi, UK’s Information
www.congress.gov/116/bills/hr3875/BIL Authority Publishes Guidance on Facial Commissioner Issues Opinion on Use
LS-116hr3875ih.pdf Recognition (Nov. 18, 2019), of Live Facial Recognition Technology
14 S. 847, 116th Cong. (2019), available at www.insideprivacy.com/data- by Police Forces (Nov. 5, 2019),
www.congress.gov/116/bills/s847/BILL privacy/french-supervisory-authority- www.insideprivacy.com/data-privacy/ai-
S-116s847is.pdf publishes-guidance-on-facial- iot-update-uks-information-
15 A.B. 2261, 2019–2020 Leg., Reg. Sess. recognition commissioner-issues-opinion-on-use-
(Cal. 2020), available at 23 See European Data Protection Board, of-live-facial-recognition-technology-by-
leginfo.legislature.ca.gov/faces/billText Guidelines 3/2019 on processing of police-forces/
Client.xhtml?bill_id=201920200AB2261 personal data through video devices 29 European Commission, White Paper:
16 A.B. 3625, 219th Leg. (N.J. 2020), (Jan. 30, 2020), edpb.europa.eu/our- Artificial Intelligence - A European
available at work-tools/our-documents/guidelines/ approach to excellence and trust (Feb.
www.njleg.state.nj.us/2020/Bills/A4000/ guidelines-32019-processing-personal- 19, 2020), COM(2020) 65 final,
3625_I1.PDF data-through-video_en. ec.europa.eu/info/sites/info/files/commi
17 H.B. 492, 65th Leg., 2d Reg. Sess. 24 European Data Protection Board, Facial ssion-white-paper-artificial-intelligence-
(Idaho 2020), available at Recognition in School Renders feb2020_en.pdf
legislature.idaho.gov/sessioninfo/2020/l Sweden’s First GDPR Fine (Aug. 22, 30 Id. at 22.
Joint investigation into Clearview’s use of facial
recognition
The Privacy Commissioner of Canada about whether the company is collect- province and territory have also
and the Privacy Commissioners in the ing and using personal information agreed to work together to develop
provinces of Quebec, British Columbia without consent. “Media reports have guidance for organizations – includ-
and Alberta have announced that they stated that Clearview AI is using its ing law enforcement – on the use of
will jointly investigate Clearview AI and technology to collect images and make biometric technology, including facial
its use of facial recognition technology. facial recognition available to law recognition.”
The investigation was initiated in enforcement for the purposes of • See www.priv.gc.ca/en/opc-news/
the wake of numerous media reports identifying individuals,” the DPAs say. news-and-announcements/2020/an
that have raised questions and concerns “Privacy regulators in every _200221/
OQ======= ^mofi=OMOM= ==============PRIVACY LAWS & BUSINESS INTERNATIONAL REPORT © 2020 PRIVACY LAWS & BUSINESSESTABLISHED
1987
Indonesia’s DP Bill lacks a
DPA, despite GDPR similarities
Issue 164 APRIL 2020
COMMENT
I
Graham Greenleaf and Andin Aditya Rahman of Assegaf Hamzah
2 -DPAs respond to Covid-19
& Partners, Indonesia, analyse the Bill’s provisions. NEWS
ndonesia’s long-awaited com- Johnny G. Plate announced the sub- 1 - Finland invests in EU cooperation
prehensive draft Law on the Pro- mission on 28 January 2020 and was 28 - Whim app and personal data
tection of Personal Data (“the summoned by the House to elabo-
Bill”) has been submitted by rate on the Bill in a formal meeting at
ANALYSIS
President Joko Widodo to the Chair- the end of February, after which he 16 - Canada: More enforcement powers?
person of the Indonesian House of stated that he expected the Bill will 18 - Digital Identity in Africa, Middle East
Representatives. Minister of Com- 22 - Facial recognition laws in US and EU
munication and Information, Continued on p.3 30 Gender equality in privacy rights
Finland invests in European
LEGISLATION
cooperation, prepares to fine
1 - Indonesia’s DP Bill lacks a DPA
13 - Dubai to update its DP law
26 - Iran moves to protect personal data
Finland’s DPA’s workload has stabilised after the immediate post-
A
MANAGEMENT
GDPR rush. The first GDPR fines are now in the pipeline. 9 - IKEA invests in data ethics
Laura Linkomies reports from Helsinki. 10 - Ethics – escaping the ivory tower
s Finland prepares to issue its across EU member states regarding NEWS IN BRIEF
first administrative fines the size of fines.
under the GDPR, most There was some delay in setting
12 - CCPA enforcement to start in July
likely by the beginning of May, the up the administrative structure to 12 - EU issues White Paper on AI
Data Protection Ombudsman, Reijo enable the issuing of fines. Anu Talus, 12 - EU Parliament committee on AI
Aarnio, says that it is of paramount 15 - Sweden fines Google €7 million
importance to achieve consistency Continued on p.7 15 - Telecoms data plan to monitor
spread of coronavirus in EU
21 - Google RTBF fine cancelled in France
Covid-19 delays PL&B Events 21 - Belgium’s DPA on direct marketing
association €525,000
21 - Netherlands’ DPA fines tennis
• Nowhere to Hide, PL&B’s 33rd • We have also postponed
Annual International Germany’s Data Protection Law:
Conference, will transfer from Trends, Opportunities & Conflicts, 24 - Clearview’s use of facial recognition
Cambridge to London and from to be hosted by Covington & 25 - EU GDPR review delayed
summer to autumn. Please see Burling in London, from March, 25 - Israel tracks people’s movements to
www.privacylaws.com/ac for a until the autumn. See battle coronavirus infections
speaker list and details of their www.privacylaws.com/germany
sessions. 25 - Global DPAs: Data protection does
not stop data sharing for Covid-19
privacylaws.com purposes
PL&B Services: Conferences • Roundtables • Content Writing
Recruitment • Consulting • Training • Compliance Audits • Research • ReportsCOMMENT
DPAs respond to Covid-19
ISSUE NO 164 APRIL 2020
PUBLISHER
We are all affected by the coronavirus pandemic, and not least in our
Stewart H Dresner
private lives. Suddenly restrictions to civil liberties that would have
stewart.dresner@privacylaws.com
EDITOR seemed draconian feel acceptable if suitable safeguards are provided, for
Laura Linkomies example, using mobile phone data to monitor the spread of the virus
laura.linkomies@privacylaws.com (p.15) by means of tracking our movements. It is pleasing that the
DEPUTY EDITOR global DPA community has concluded that data protection law does
Tom Cooper not stop data sharing for Covid-19 purposes (p.25) – but at the same
tom.cooper@privacylaws.com time we need to stay vigilant that the current exceptions do not become
the norm in future. DPAs have issued statements and guidance on the
coronavirus situation for organisations whose privacy compliance
ASIA-PACIFIC EDITOR
teams are now often working remotely. Much of that is related to the
Professor Graham Greenleaf
kind of data which can be gathered on employees, but there is also
graham@austlii.edu.au
REPORT SUBSCRIPTIONS guidance on how to manage data security issues for remote workers. In
K’an Thomas addition, the European Union Agency for Cybersecurity (ENISA) on
24 March issued its top tips for cybersecurity when working remotely.
kan@privacylaws.com
CONTRIBUTORS
Andin Aditya Rahman For everyone who has suddenly needed to take up new technologies to
Assegaf Hamzah & Partners, Indonesia organise virtual meetings, Zoom has become a popular option.
Nick Rhodes However there have been reports of Zoom’s bad track record with data
BAE Systems Applied Intelligence, UK protection measures. Zoom has defended itself by saying that “No data
regarding user activity on the Zoom platform – including video, audio,
Colin J. Bennett
and chat content – is ever provided to third parties for advertising
University of Victoria, Canada
purposes.” In the US, a class action lawsuit has been launched, and on
Tripti Dhar
1 April the Hong Kong Privacy Commissioner for Personal Data
Reina Legal LLP, India
Oliver Butler
Oxford University, UK made data security recommendations to Zoom users.
Tayebeh Saheb
Modares University, Iran Before the travel restrictions kicked in, I was in Finland to interview
Elizabeth Coombs the Ombudsman and his Deputy (p.1), and a travel app company
Whim (p.28). Other articles in this issue include a world first analysis
UN SRP Taskforce
(in English) of Indonesia’s new data protection Bill (p.1), updates on
Sam Choi, Hannah Lepow, Christopher Lin,
Canada (p.16), Iran (p.26), Dubai (p.13), data ethics (p.10), facial
and Jadzia Pierce
Covington & Burling LLP, US
Published by recognition (p.22), and privacy aspects of gender equality (p.30). In
Privacy Laws & Business, 2nd Floor, this issue, we also report on digital identity developments in Africa and
Monument House, 215 Marsh Road, Pinner, the Middle East (p.18).
Middlesex HA5 5NE, United Kingdom
Unfortunately, we have had to move Nowhere to Hide, PL&B’s 33rd
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Annual International Conference from Cambridge to London and
Email: info@privacylaws.com
Website: www.privacylaws.com
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Report is produced six times a year and is available on an
Most speakers will be, in principle, available for our conference, which
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Whilst every care is taken to provide accurate information, the we can arrange only when social distancing stops and travel starts.
Laura Linkomies, Editor
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