Use of Facial Recognition Technology - Staff Report - May 9, 2025

Sep 18, 2026

Report on the Transportation Security Administration’s use of facial recognition technology to determine air traveler identity for security purposes. The Privacy and Civil Liberties Oversight Board staff summarizes key program aspects, reviews operations, and evaluates privacy and civil liberties risks, then provides recommendations to improve the program. The analysis notes that, as deployment is still underway, there is insufficient evidence to support a fully detailed policy analysis for some topics, so further information-collection efforts are recommended.

LanguageEnglish

CategoryResearch & Report

FormatPDF

Pages125

Reading Time5 h 15 min

AccessFree to download

Executive Summary

Part 1: Background, System Description, and Operations

I. Report Overview

II. Background on Facial Recognition Technology

III. Legal and Regulatory Context

IV. Aviation Security and TSA Use of FRT

V. TSA Policy and Standards for Operations of CAT-2 Devices for Determining Traveler Identity

Part 2: Policy Analysis

I. Introduction to Policy Analysis

II. Effectiveness and Value

III. Consequences of Misidentification and Demographic Impacts

IV. Transparency and Public Notice

V. Individual Rights and Notice

VI. Collection, Sharing, Retention, and Use of Data

VII. Safeguards Against Expansion or Misuse

VIII. Conclusions

Part 3: Recommendations

I. Overall Program

II. Effectiveness and Value

III. Demographics and Consequences of Misidentification

IV. Transparency

V. Individual Participation

[T H I S PA G E I N T E N T I O N A L L Y L E F T B LA N K ] THE PRIVACY AND CIVIL LIBERTIES OVERSIGHT BOARD USE OF FACIAL RECOGNITION TECHNOLOGY BY THE TRANSPORTATION SECURITY ADMINISTRATION STAFF REPORT MAY 9, 2025 Privacy and Civil Liberties Oversight Board Beth A. Williams, Board Member PCLOB acknowledges with gratitude the staff members who worked on this project, including Paige Anderson, Bonni Berge, Pamela Brooke, Cameron Brown, Hannah Burgess, Geoff Cohen, Jennifer Fitzpatrick, Clare Garvie, David Husband, John Leitner, Aaron Massey, Annan Mortensen, Tatjana Naquin, Alexa Potter, Alan Silverleib, and other current and former staff members. STATEMENT FROM THE PCLOB STAFF In 2019, the Privacy and Civil Liberties Oversight Board (“PCLOB,” or “the Board”) opened an oversight project on facial recognition and other biometric technologies in aviation security. PCLOB’s professional staff, under the direction of PCLOB Board members, reviewed program documentation, reports, and evaluations, and worked with Department of Homeland Security offices to understand the operations of the program. This report describes the key aspects of the Transportation Security Administration’s (TSA) use of facial recognition technology (FRT) to determine the identity of air travelers for security purposes. We also include an analysis of potential associated privacy and civil liberties risks and make recommendations to improve the program. The Board is currently sub-quorum, so PCLOB is issuing this report as a Staff Report, with the approval of the current Board member, per the Board’s Sub-Quorum Authorities policy. The professional staff made all final decisions with respect to this report, including selecting the topics and recommendations to include. Over the course of investigating this program and developing this report, current and former Board members and staff considered many potential topics of analysis and recommendations. Consistent with general government practice, the professional staff included only those findings and recommendations which were supported by sufficient, appropriate evidence. As a program still in the process of development and deployment, TSA’s use of FRT has not had sufficient opportunity to produce a detailed record of impact and efficacy. As such, PCLOB could not perform a thorough policy analysis for certain aspects of the program. For this reason, this report recommends that TSA make further efforts to collect information regarding the operations and performance of the program. Topics and recommendations considered, but ultimately not incorporated into this report, include issues related to program cybersecurity, additional policies and practices around signage and notice, and mechanisms for travelers to indicate affirmative opt-in consent. The absence of any particular topic or recommendation does not necessarily indicate that the staff disagree with the analysis or recommendation, but only that at this time, the staff does not assess that the available evidence provides a reasonable and sufficient basis for inclusion. PCLOB is not the only entity examining this program, and we welcome continued conversation with Congress, other oversight bodies, TSA, civil society, and the public as the program continues to develop. Jennifer Fitzpatrick PCLOB Executive Director May 9, 2025 TABLE OF CONTENTS E X E C U T I V E S U M M A R Y ................................ ................................ ................ 1 P A R T 1 : B A C K G R O U N D , S Y S T E M D E S C R I P T I O N , A N D O P E R A T I O N ..... 9 I . R E P O R T O V E R V I E W ...................................................................... 10 II . B A C K G R O U N D O N FA C I A L R E C O G N I T I O N T E C H N O L O G Y .................... 14 III . L E G A L A N D R E G U L A T O R Y C O N T E X T ............................................... 22 IV . A V I A T I O N S E C U R I T Y A N D

FAQs

What is the purpose of the staff report on TSA’s facial recognition technology?

The report describes key aspects of TSA’s use of facial recognition technology for traveler identity determination and analyzes associated privacy and civil liberties risks, along with recommendations to improve the program.

Why does the report state that a thorough policy analysis could not be completed for some topics?

TSA’s use of facial recognition technology is still in development and deployment, so there has not been sufficient opportunity to produce a detailed record of impact and efficacy.

What kinds of topics and recommendations were considered but not included in the report?

The report notes that topics considered but not incorporated include issues related to program cybersecurity, additional signage and notice policies and practices, and mechanisms for travelers to indicate affirmative opt-in consent.

Sep 18, 2026

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