The Privacy Advocate – Should the Facial Recognition Code Apply to the Gov’t? Could It?
“Enrollment could be to ensure the same delivery guy comes in every day at 2 p.m. so enrollment is like saving (an image),” DelBianco said. “The user of the system took a template and enrolled it. That’s different from saving. They might have compared it with other residents of the building to see if they should be able to get in. What level of transparency do we give to the subject about those two activities?”
Susan Grant of the Consumer Federation of America said she thought “storage” was the same as “enrollment,” and that the group had decided that as soon as storage happened, consent should be required.
Calabrese said his concerns revolve around when a person is enrolled into a database—regardless of whether the image is shared.
“For my mind, if I’m taking an image, I’m turning it into a template,” he said. “That raises all these issues at that point. That’s the logical use for notice, consent and transparency.”
NetChoice’s DelBianco said it may be logistically impossible to be completely transparent at the time of “enrollment.” How do you notify every image subject that their image has been taken at the time of the capture?
“Practically speaking, that’s going to be very challenging,” he said.
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Carl Szabo of NetChoice proposed the group spend one more meeting fleshing out details and then get down to writing a code.