Provision record
Plaid · Plaid End User Privacy Policy · View original document ↗

Biometric Data Collection and Retention

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Document Record

What it is

The policy discloses that Plaid may collect photographs, videos, and facial geometry scans for identity verification purposes, and that this data may constitute biometric data in certain jurisdictions. For Illinois and Texas residents specifically, the policy states facial geometry data will be stored for no longer than three years unless otherwise required by law.

This analysis describes what Plaid'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)

This provision discloses biometric data collection practices that are subject to specific statutory requirements in Illinois under BIPA and in Texas under the Capture or Use of Biometric Identifier Act; compliance with these statutes requires written consent prior to collection, specified retention schedules, and destruction obligations, and the three-year retention period stated in the policy should be evaluated against each statute's requirements.

Interpretive note: The policy's three-year retention period for biometric data may not align with BIPA's earliest-date destruction standard (destruction upon fulfillment of purpose or within three years of last interaction, whichever is earlier); the practical application of the retention period depends on how Plaid defines the fulfillment of the collection purpose.

Recent Activity

This document changed recently

High Apr 21, 2026

End consumers may see their financial data accessed by a broader range of people under developer accounts, but Plaid now requires developers to formally designate and manage these 'Authorized Users' and take responsibility for their conduct. The introduction of session replay and activity monitoring means developer interactions with your financial data may be recorded for audit or security purposes. The policy does not specify what data is covered by monitoring or how long recordings are retained, which creates operational uncertainty for developers handling sensitive consumer financial information.

View change record →
Medium Apr 19, 2026

Plaid's updated terms establish a new direct relationship with you through the Plaid Account and introduce a monitoring service that operates through a web app. The terms now authorize Plaid to share financial information needed for third-party apps to initiate payments to or from you, which is a broader statement of data-sharing scope than the previous language. This means Plaid's role shifts from primarily facilitating connections to third-party apps toward directly providing account services, including monitoring. The effective date is April 14, 2026, though the change was detected on April 19, 2026. Review your Plaid Account settings to understand what data Plaid holds and how the monitoring service works.

View change record →
Medium Apr 3, 2026

The updated terms clarify that Plaid may request and collect phone numbers, email addresses, and other contact information when you connect financial accounts or verify your identity through a Plaid-connected application. The terms no longer describe a separate Plaid Monitoring Service or Plaid Web-App. The Plaid Account is now framed primarily as a tool to accelerate onboarding and use of third-party applications rather than as a standalone service for monitoring and alerts. The updated language authorizes Plaid to store identity verification data within your Plaid Account if you choose to do so.

View change record →

Clause Stability Stable

0
Changes
3
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

Under these terms, Plaid may collect facial photographs or video and derive biometric identifiers (facial geometry scans) for identity verification, and this data may be retained for up to three years for Illinois and Texas residents. The policy refers users to a separate Biometric Policy and Release document for additional details on how this data is treated.

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
    Email privacy@plaid.com to request deletion of biometric data collected during identity verification; you may also submit a request through Plaid's online data rights form referenced in the privacy policy.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
We may also collect certain documentation that contains your photograph or we may require you to verify your identity by providing a photograph or video of yourself, for more information please see Plaid's Biometric Policy and Release. Data collected in this context may be considered biometric data in some states or countries. Special Biometric Data Notice for Illinois and Texas Residents For residents of Illinois or Texas, if we require you to provide us with any document that contains your photograph or if you need to verify your identity by providing a photograph or video of yourself, the data derived from your face that we collect and process, and that our service providers collect and process on our behalf, may be considered biometric data in some places. Your data will be stored no longer than three years, unless otherwise required by law.

Excerpt from Plaid's End User Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1. REGULATORY LANDSCAPE: This provision directly implicates the Illinois Biometric Information Privacy Act (BIPA) and the Texas Capture or Use of Biometric Identifier Act (CUBI), both of which impose written consent, retention schedule, and destruction requirements for biometric data. BIPA provides a private right of action with statutory damages, making it a material litigation risk for companies collecting facial geometry data from Illinois residents. GDPR Article 9 governs biometric data as a special category of personal data for EEA users, requiring explicit consent or another Article 9(2) exception as a lawful basis. 2. GOVERNANCE EXPOSURE: High. The collection of facial geometry data from identity verification processes creates specific statutory compliance obligations in Illinois and Texas, where non-compliance can result in significant statutory damages under BIPA's private right of action. The policy's three-year retention limit for Illinois and Texas residents should be evaluated against BIPA's requirement that biometric data be destroyed when the purpose for collection has been fulfilled or within three years of last interaction, whichever is earlier. 3. JURISDICTION FLAGS: Illinois presents the highest litigation exposure due to BIPA's private right of action; class actions under BIPA have resulted in substantial settlements in the financial and technology sectors. Texas CUBI does not provide a private right of action but is enforceable by the Texas Attorney General. Other US states including Washington and potentially California may also regulate facial geometry or biometric data, and the policy's disclosure that collection may be biometric in some states suggests broader applicability than Illinois and Texas alone. EEA and UK users are covered under GDPR Article 9's special category protections. 4. CONTRACT AND VENDOR IMPLICATIONS: The policy states that service providers collect and process biometric data on Plaid's behalf; organizations deploying Plaid for identity verification should confirm that their vendor agreements with Plaid include appropriate data processing terms for biometric data, including retention and destruction obligations consistent with BIPA and CUBI requirements. Indemnification and liability allocation for BIPA claims should be explicitly addressed in any commercial agreement with Plaid. 5. COMPLIANCE CONSIDERATIONS: Organizations deploying Plaid's identity verification features should assess whether their own user-facing disclosures and consent mechanisms satisfy BIPA's written consent requirement prior to collection of biometric data from Illinois residents. A data mapping exercise should confirm the categories of biometric data collected by Plaid's service providers, the retention schedules applied, and the destruction processes in place, and should document how these align with BIPA's earliest-date destruction standard.

Full institutional analysis

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

Applicable agencies

  • State AG
    The Illinois Attorney General and Texas Attorney General have enforcement authority over BIPA and CUBI respectively, both of which directly regulate the biometric data collection practices disclosed in this provision.
    File a complaint →
  • FTC
    The FTC has authority over unfair or deceptive practices relating to biometric data collection and may review whether disclosures and consent mechanisms for facial geometry collection are adequate.
    File a complaint →

Provision details

Document information
Document
Plaid End User Privacy Policy
Entity
Plaid
Document last updated
May 5, 2026
Tracking information
First tracked
May 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-014834
Document ID
CA-D-00169
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
0a8d827572962cc5012319c796e08d8fb49190be40484061ff10c08cf6718f4b
Analysis generated
May 9, 2026 15:51 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Plaid
Document: Plaid End User Privacy Policy
Record ID: CA-P-014834
Captured: 2026-05-09 15:51:01 UTC
SHA-256: 0a8d827572962cc5…
URL: https://conductatlas.com/platform/plaid/plaid-end-user-privacy-policy/provision/CA-P-014834/biometric-data-collection-and-retention/
Accessed: July 25, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

Other risks in this policy

Governance intelligence across arbitration, AI governance, data rights, indemnification, and retention

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Frequently Asked Questions

What does Plaid's Biometric Data Collection and Retention clause do?

This provision discloses biometric data collection practices that are subject to specific statutory requirements in Illinois under BIPA and in Texas under the Capture or Use of Biometric Identifier Act; compliance with these statutes requires written consent prior to collection, specified retention schedules, and destruction obligations, and the three-year retention period stated in the policy should be evaluated against each …

How does this clause affect you?

Under these terms, Plaid may collect facial photographs or video and derive biometric identifiers (facial geometry scans) for identity verification, and this data may be retained for up to three years for Illinois and Texas residents. The policy refers users to a separate Biometric Policy and Release document for additional details on how this data is treated.

Is ConductAtlas affiliated with Plaid?

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