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
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.
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.
How other platforms handle this
to request that your data be transferred to a third party (data portability)
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.
To stop us collecting your location information, you can update your device settings, stop using the Service, or uninstall our mobile apps.
"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
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 …
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Search "[your state] attorney general consumer complaint" to find your state's direct complaint form
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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.
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 …
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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