Provision record
Delta Airlines · Delta Privacy Policy · View original document ↗

Biometric Data Collection for Voluntary Identity Programs

High severity Medium confidence Inferred from context Common · 290 of 352 platforms
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Document Record

What it is

If you choose to use Delta's optional biometric boarding or identity verification programs, Delta collects and processes biometric data such as your facial scan to confirm your identity at the airport.

This analysis describes what Delta Airlines'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)

Biometric data like facial recognition is among the most sensitive categories of personal information because it is unique, immutable, and cannot be changed if compromised; state laws impose strict requirements around its collection, use, and retention.

Interpretive note: The specific retention periods, vendor arrangements, and written consent mechanisms for Delta's biometric programs are not fully detailed in the visible policy text; the full extent of compliance with state biometric statutes cannot be confirmed from this document alone.

Clause Stability Stable

0
Changes
3
Months Monitored
May 9, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 5149 other provisions on other platforms.

Consumer impact (what this means for users)

Enrolling in Delta's optional biometric boarding programs means Delta and potentially its technology partners (such as the U.S. Customs and Border Protection or third-party vendors) will collect and retain your facial recognition data, which is governed by state biometric privacy laws in Illinois, Texas, and other states that may confer private rights of action or require specific written consent before collection.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    Visit Delta's Privacy and Security page and submit a data deletion request for biometric data. You may also opt out of biometric boarding programs at the airport by notifying a Delta representative before the program is used.

How other platforms handle this

Square Medium

to request that your data be transferred to a third party (data portability)

Google Cloud Medium

Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.

Roblox Medium

To stop us collecting your location information, you can update your device settings, stop using the Service, or uninstall our mobile apps.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
Delta may participate in voluntary programs that use biometric identifiers, such as facial recognition technology, to verify your identity at the airport. Participation in these programs is voluntary, and you may opt out by notifying a Delta representative.

Excerpt from Delta Airlines's Delta Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

REGULATORY LANDSCAPE: Biometric data collection engages multiple state statutes, most significantly the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act (CUBI), and the Washington My Health MY Data …

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

Applicable regulations

EU AI Act
European Union
CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Delta Privacy Policy
Entity
Delta Airlines
Document last updated
May 5, 2026
Tracking information
First tracked
May 7, 2026
Last verified
May 9, 2026
Record ID
CA-P-007212
Document ID
CA-D-00629
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
8457cf035cfa0c5237d80b10b4c903590ea2ec5f3361da5dd4a6cf53812f2c41
Analysis generated
May 7, 2026 05:33 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Delta Airlines
Document: Delta Privacy Policy
Record ID: CA-P-007212
Captured: 2026-05-07 05:33:19 UTC
SHA-256: 8457cf035cfa0c52…
URL: https://conductatlas.com/platform/delta-airlines/delta-privacy-policy/provision/CA-P-007212/biometric-data-collection-for-voluntary-identity-programs/
Accessed: Aug. 11, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Delta Airlines's Biometric Data Collection for Voluntary Identity Programs clause do?

Biometric data like facial recognition is among the most sensitive categories of personal information because it is unique, immutable, and cannot be changed if compromised; state laws impose strict requirements around its collection, use, and retention.

How does this clause affect you?

Enrolling in Delta's optional biometric boarding programs means Delta and potentially its technology partners (such as the U.S. Customs and Border Protection or third-party vendors) will collect and retain your facial recognition data, which is governed by state biometric privacy laws in Illinois, Texas, and other states that may confer private rights of action or require specific written consent before …

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.

Is ConductAtlas affiliated with Delta Airlines?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Delta Airlines.