Equifax · Equifax Privacy Policy · View original document ↗

Biometric Data Collection

High severity Medium confidence Explicitdocumentlanguage Uncommon · 18 of 325 platforms
Share 𝕏 Share in Share 🔒 PDF
Monitor governance changes for Equifax Create a free account to receive the weekly governance digest and monitor one platform for governance changes.
Create free account No credit card required.
Document Record

What it is

Equifax states it may collect biometric data such as fingerprints, voice recordings, and facial geometry to verify your identity when you contact the company online or by phone.

This analysis describes what Equifax'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 is among the most sensitive personal information because it cannot be changed if compromised. Several states have strict laws governing how companies may collect, store, and share biometric identifiers.

Interpretive note: The policy discloses biometric collection but does not specify whether state-specific consent mechanisms such as those required under Illinois BIPA are implemented, creating uncertainty about whether disclosed practices meet statutory requirements in all applicable jurisdictions.

Consumer impact (what this means for users)

If Equifax collects your biometric information for identity verification, that data could be retained and, depending on how the policy is applied, shared with service providers. Illinois, Texas, and Washington impose specific consent and retention requirements for biometric data that may affect how these terms apply to residents of those states.

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 the Equifax privacy rights portal, select the option to submit a data deletion request, and specify biometric data as the category you wish to have deleted.

How other platforms handle this

PlanetScale Medium

When you visit the Careers portion of our websites, we collect the information that you provide to us in connection with your job application. This includes but is not limited to business and personal contact information, professional credentials and skills, educational and work history and other in...

American Airlines Medium

American does not knowingly collect personal information directly from children – persons under the age of 13, or another age if required by applicable law – other than when required to comply with the law or for safety and security reasons. Due to the nature of our Services, we may collect travel i...

GOAT Medium

We may collect information about your location, including precise geolocation information, when you use our Services. We use this information to provide location-based services, such as showing you products available in your area, and for other purposes described in this Privacy Policy.

See all platforms with this clause type →

Monitoring

Equifax has changed this document before.

Receive same-day alerts, structured change summaries, and monitoring for up to 10 platforms.

Start Watcher free trial Or create a free account →
▸ View Original Clause Language DOCUMENT RECORD
"
Biometric information: Biometric information (such as fingerprints, voice recordings, facial geometry, iris or retina scans) that can be used to identify you. We may collect biometric information to verify your identity when you interact with us online or by phone.

— Excerpt from Equifax's Equifax Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: This provision directly engages the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act (CUBI), and the Washington My Health MY Data Act to the extent biometric data intersects with health-adjacent processing. Illinois BIPA requires written consent before collection, a publicly available retention schedule, and prohibits sale of biometric identifiers. The FTC also holds general authority over deceptive or unfair data practices under Section 5 of the FTC Act. Where the policy asserts collection and use of biometric data without specifying state-by-state consent mechanisms, tension exists with BIPA's requirements. GOVERNANCE EXPOSURE: High. BIPA has generated significant class action litigation with statutory damages of $1,000 to $5,000 per violation. The policy discloses biometric collection but does not specify whether separate written consent is obtained from Illinois residents as BIPA requires. This gap between policy disclosure and statutory consent requirements represents material litigation exposure. JURISDICTION FLAGS: Heightened exposure in Illinois (BIPA), Texas (CUBI), Washington, and California (CPRA designates biometric data as sensitive personal information requiring opt-in for certain uses). The policy does not specify jurisdiction-specific consent mechanisms, which may be insufficient to satisfy state biometric laws. CONTRACT AND VENDOR IMPLICATIONS: Any service provider that processes biometric data on Equifax's behalf must be assessed for BIPA-compliant data handling, including prohibition on sale and destruction schedules. Vendor agreements should include explicit biometric data handling obligations and indemnification clauses. COMPLIANCE CONSIDERATIONS: Legal teams should audit whether written consent is obtained from Illinois residents prior to biometric collection, confirm whether a biometric retention and destruction schedule has been published as required by BIPA, and assess whether voice recordings used for phone verification meet the statutory definition of biometric identifiers under applicable state laws. Data mapping should separately track biometric data flows distinct from other personal information categories.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

Track 1 platform — free Try Watcher free for 14 days

Free: track 1 platform + weekly digest. Watcher: 10 platforms + same-day alerts. No credit card required.

Applicable agencies

  • FTC
    The FTC has authority over unfair or deceptive data collection practices including biometric data, and Equifax is a regulated entity under the FTC Act
    File a complaint →
  • State AG
    State attorneys general in Illinois, Texas, and Washington have enforcement authority under their respective biometric privacy statutes
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
ePrivacy Directive
European Union
FCRA
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
GLBA
United States Federal
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
Equifax Privacy Policy
Entity
Equifax
Document last updated
May 5, 2026
Tracking information
First tracked
May 8, 2026
Last verified
May 11, 2026
Record ID
CA-P-010373
Document ID
CA-D-00591
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
a763bcb4921c4fbb345d76dfa0c84dc0451d890793ef3b8d244674596ec31df4
Analysis generated
May 8, 2026 15:21 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Equifax
Document: Equifax Privacy Policy
Record ID: CA-P-010373
Captured: 2026-05-08 15:21:58 UTC
SHA-256: a763bcb4921c4fbb…
URL: https://conductatlas.com/platform/equifax/equifax-privacy-policy/biometric-data-collection/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

Other risks in this policy

Related Analysis

Professional Governance Intelligence

Need to monitor specific governance provisions?

Professional includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.

Arbitration clauses AI governance Data rights Indemnification Retention policies
Start Professional free trial

Or start with Watcher →

Built from archived source documents, structured governance mappings, and historical version tracking.

Frequently Asked Questions

What does Equifax's Biometric Data Collection clause do?

Biometric data is among the most sensitive personal information because it cannot be changed if compromised. Several states have strict laws governing how companies may collect, store, and share biometric identifiers.

How does this clause affect you?

If Equifax collects your biometric information for identity verification, that data could be retained and, depending on how the policy is applied, shared with service providers. Illinois, Texas, and Washington impose specific consent and retention requirements for biometric data that may affect how these terms apply to residents of those states.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 18 platforms. See the full comparison.

Is ConductAtlas affiliated with Equifax?

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