Chase · Chase Deposit Account Agreement · View original document ↗

Trusted Device Enrollment and Biometric Data Collection

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Document Record

What it is

Chase may require customers to enroll a trusted mobile device to access certain account services, payment functions, and wire transfers; enrollment may require submitting a photo of a government-issued ID and biometric data such as a selfie. Chase retains identity document images and biometric data to the extent permitted by applicable law.

This analysis describes what Chase's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

The collection and retention of biometric data (selfie) and government-issued identity document images during trusted device enrollment implicates state biometric privacy statutes including the Illinois Biometric Information Privacy Act (BIPA) and similar laws in Texas and Washington. The agreement's retention limitation to 'the extent permitted by applicable law' does not specify retention periods or destruction timelines, which are required disclosures under BIPA and comparable statutes.

Interpretive note: The specific retention period and destruction schedule for biometric data and identity document images are not stated in the agreement text and are deferred to applicable law and the privacy policy, creating interpretive uncertainty about whether specific statutory requirements such as BIPA are fully addressed.

Clause Stability Stable

0
Changes
4
Months Monitored
Jul 13, 2026
First Seen
Jul 13, 2026
Last Seen

Consumer impact (what this means for users)

This provision authorizes Chase to collect biometric data and identity document images as part of trusted device enrollment, which may be required to access wire transfers, payments, and certain account services. The agreement states that identity document images will be stored only to the extent permitted by applicable law, but does not specify retention periods or destruction schedules in the agreement text.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
To help protect your account, we may require that you use a trusted device to: Manage your account and/or digital profile, Access certain account services, Make certain payments and transfers, or Authorize or approve payments and transfers. A trusted device is an eligible device that has been successfully enrolled with us based on specific criteria we set and may modify from time to time in our sole discretion... During the process of making your eligible device a trusted device, we may require you to verify your identity and authenticate by taking certain actions, which may include, but are not limited to, one or more of the following: Taking a photo with your mobile phone camera of your acceptable form of identification; Entering information from your debit card (e.g., CVV), or Providing biometrics (e.g., selfie), or Using a token where available. Valid driver's licenses and state identifications qualify as acceptable forms of identification; additional qualifying forms of identification may be added by us periodically. The image of your identification will be stored or retained only to the extent permitted by applicable law and will be used as permitted under our privacy policy.

Excerpt from Chase's Deposit Account Agreement

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1. REGULATORY LANDSCAPE: Biometric data collection implicates the Illinois Biometric Information Privacy Act (BIPA), which requires written informed consent, a publicly available retention and destruction policy, and prohibits sale or profit from biometric data. Texas and Washington have similar statutes. The agreement's reference to retaining data 'to the extent permitted by applicable law' and 'as permitted under our privacy policy' may satisfy disclosure requirements in some jurisdictions but the agreement text alone does not reproduce the specific retention and destruction schedule required by BIPA. State AGs in Illinois, Texas, and Washington have enforcement authority. 2. GOVERNANCE EXPOSURE: High for customers in Illinois, Texas, and Washington. The collection of selfie biometric data during account enrollment creates direct BIPA exposure if the written consent and retention policy requirements are not separately satisfied outside of this agreement text. BIPA provides a private right of action with statutory damages of $1,000 to $5,000 per violation. 3. JURISDICTION FLAGS: Illinois (BIPA), Texas (Capture or Use of Biometric Identifier Act), and Washington (My Health MY Data Act and biometric privacy provisions) create heightened exposure. California's CCPA and CPRA include biometric information as sensitive personal information subject to additional disclosure and opt-out rights. The agreement notes that tablets, laptops, and desktop computers are not eligible trusted devices, limiting enrollment to mobile smartphones. 4. CONTRACT AND VENDOR IMPLICATIONS: Third-party identity verification vendors involved in the trusted device enrollment process should be assessed for compliance with applicable biometric privacy statutes as data processors. Vendor contracts should include appropriate data processing agreements and deletion obligations. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should confirm that a standalone biometric data retention and destruction policy satisfying BIPA requirements is publicly available and linked from the digital enrollment flow. Consent mechanisms during trusted device enrollment should be audited to confirm they satisfy written consent requirements under applicable state law. The retention limitation language should be mapped against specific state law timelines.

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Applicable agencies

  • State AG
    State attorneys general in Illinois, Texas, and Washington have enforcement authority over biometric privacy statutes that may apply to the biometric data collection described in this provision
    File a complaint →
  • FTC
    The FTC has authority over unfair or deceptive data collection and retention practices under Section 5 of the FTC Act
    File a complaint →

Provision details

Document information
Document
Chase Deposit Account Agreement
Entity
Chase
Document last updated
May 5, 2026
Tracking information
First tracked
July 13, 2026
Last verified
July 13, 2026
Record ID
CA-P-076280
Document ID
CA-D-00041
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
883891961b3aeca39efb9b814f4308f4a0993e9296cb08cc30abce6337e5f818
Analysis generated
July 13, 2026 01:49 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Chase
Document: Chase Deposit Account Agreement
Record ID: CA-P-076280
Captured: 2026-07-13 01:49:00 UTC
SHA-256: 883891961b3aeca3…
URL: https://conductatlas.com/platform/chase/chase-deposit-account-agreement/provision/CA-P-076280/trusted-device-enrollment-and-biometric-data-collection/
Accessed: July 23, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Chase's Trusted Device Enrollment and Biometric Data Collection clause do?

The collection and retention of biometric data (selfie) and government-issued identity document images during trusted device enrollment implicates state biometric privacy statutes including the Illinois Biometric Information Privacy Act (BIPA) and similar laws in Texas and Washington. The agreement's retention limitation to 'the extent permitted by applicable law' does not specify retention periods or destruction timelines, which are required disclosures …

How does this clause affect you?

This provision authorizes Chase to collect biometric data and identity document images as part of trusted device enrollment, which may be required to access wire transfers, payments, and certain account services. The agreement states that identity document images will be stored only to the extent permitted by applicable law, but does not specify retention periods or destruction schedules in the …

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