GM may collect biometric data such as fingerprints or facial scans in connection with certain vehicle features, which is among the most sensitive personal data a company can collect.
This analysis describes what General Motors'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 is unique and permanent; unlike a password, it cannot be changed if compromised, making its collection and storage a significant privacy risk.
Interpretive note: The document was truncated and the full verbatim biometric collection clause could not be confirmed; this provision is inferred from the policy's disclosed data categories and standard automotive privacy policy structures. The exact scope and consent mechanism requires review of the complete document.
If GM collects your biometric data through vehicle features, this information is subject to state biometric privacy laws in Illinois and other states, which may impose consent and deletion requirements that go beyond what this policy discloses.
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"We may collect biometric information, including fingerprints or facial geometry, in connection with certain vehicle features or services.— Excerpt from General Motors's GM Privacy Statement
REGULATORY LANDSCAPE: Biometric data collection engages the Illinois Biometric Information Privacy Act (BIPA, 740 ILCS 14), which requires written consent prior to collection, a publicly available retention and destruction policy, and prohibits sale of biometric data. Texas and Washington have analogous biometric laws. CCPA/CPRA treats biometric data as sensitive personal information requiring enhanced notice and opt-out rights. BIPA has a private right of action with statutory damages of $1,000-$5,000 per violation, creating significant litigation exposure. GOVERNANCE EXPOSURE: High. The collection of biometric identifiers from vehicle occupants — who may include passengers not party to any GM service agreement — raises serious questions about adequate consent and notice. BIPA litigation against automotive and technology companies has increased substantially, and any biometric collection without state-compliant written consent and a published retention schedule creates material legal risk. JURISDICTION FLAGS: Illinois presents the highest litigation risk given BIPA's private right of action. Texas and Washington require notice and opt-out for biometric data. California CPRA requires businesses to obtain explicit consent before collecting biometric data as sensitive personal information. Several additional states are enacting or considering biometric privacy laws. CONTRACT AND VENDOR IMPLICATIONS: Any third-party service providers who process biometric data on GM's behalf must be governed by data processing agreements that include BIPA-compliant retention and destruction terms. Disclosure of biometric data to affiliates or third parties likely constitutes a 'sale' under BIPA, which is prohibited. COMPLIANCE CONSIDERATIONS: Legal teams should confirm whether a separate, BIPA-compliant written consent and retention policy exists for any Illinois vehicle owners or operators. A biometric data retention and destruction schedule should be published as required by BIPA. The policy should be reviewed to confirm it does not represent that biometric data will not be sold when the broader data sharing framework could be construed to include it.
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Biometric data is unique and permanent; unlike a password, it cannot be changed if compromised, making its collection and storage a significant privacy risk.
If GM collects your biometric data through vehicle features, this information is subject to state biometric privacy laws in Illinois and other states, which may impose consent and deletion requirements that go beyond what this policy discloses.
ConductAtlas has identified this type of provision across 2 platforms. See the full comparison.
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