New York City Council Committee on Technology 
Int. 213-2025, Prohibiting the Use of Biometric Identifiers 

Thank you, Chair De La Rosa and members of the committee, for the opportunity to testify on Int. 213 which would prohibit places or providers of public accommodation from using biometric recognition technology and restrict the collection of biometric identifier information. The Partnership for New York City represents the city’s business leaders and largest employers. Our member companies support nearly one million jobs in New York City and deliver approximately $263 billion in economic output. We work with government, labor, and the nonprofit sector to promote economic growth and maintain the city’s prominence as a global center of economic opportunity, upward mobility, and innovation. 

The Partnership supports sensible safeguards for consumers around the use of biometric information but opposes Int. 213 as currently drafted. The proposed legislation would prevent consumers from accessing the substantial benefits of biometric recognition technology. Companies use biometric recognition technology to protect consumers’ information, funds, and services. Many customers do not take sufficient measures to protect themselves. For example, they use weak passwords or the same passwords for multiple accounts. Biometric identifiers are a more secure form of protection since they cannot be lost or forgotten and are substantially more difficult to steal than a password. They also help companies prevent fraud and waste by employees. 

Biometric recognition technology is also a faster way of authenticating a customer, making security screenings easier and quicker in a variety of high-volume locations such as airports and event venues. Customers make informed choices to use these programs for a more seamless experience. Int. 213 would prohibit these programs. 

To allow companies to properly protect consumers and enable consumers to take advantage of the benefits of biometric recognition technology, the Partnership recommends the following changes to Int. 213: 

• Exempt security uses of biometric recognition technology from the ban. The current bill does not differentiate between different types of uses for this technology. Biometric recognition technology helps protect consumers from fraud and their own mistakes. Washington’s law regulating this technology includes an exemption for uses related to a “security purpose” as differentiated from a “commercial purpose.” Consumers are required to opt in for commercial uses. 

• Financial firms should be exempt from the proposed law, as they are from current law. The financial industry was exempted from the current law requiring disclosure of the collection of biometric identifiers by certain businesses because of the high levels of risk in financial transactions and the amount of security required to mitigate such risk. The use and protection of personal information by these firms are already heavily regulated by multiple levels of government. Financial institutions are broadly exempt in both Illinois’ and Washington’s laws governing biometric recognition technology. 

• Consumers should be permitted to opt-in to using a service that relies on biometric recognition technology. Int. 213 appears to prohibit voluntary uses of biometric technology (where a customer chooses to use a technology offered by a place of public accommodation for the convenience of the customer). These services already provide a high level of convenience for informed consumers in airports, stadia, etc. 

• The bill should clarify that its provisions apply to consumers and not to employees. The current law requiring disclosure of the collection of biometric identifier information applies only to customers. The language of the new bill clearly applies to customers in some places and does not specify in other places. Biometric recognition technologies are used by employers to increase security of information and facilities and to prevent fraud. They are also critical for regulatory compliance in certain industries, such as finance. 

Attached to this testimony is a list of additional changes we hope you will consider making to the proposed law. 

The Partnership is committed to working with the City Council to ensure that individuals’ information receives the highest level of protection while also allowing them to benefit from the security and convenience available through new technologies. 

Thank you.