An ecosystems approach to biometric regulation

WPF is pleased to announce the publication of new work by our Executive Director, Pam Dixon, in the March 2022 Turkish Policy Quarterly. “This journal article is an outgrowth of long work looking at what could help in the biometric ecosystem to address and mitigate the consequential risks of biometrics when used singly and in combination,” Dixon said. “We must begin thinking about biometric regulation at the ecosystem level, otherwise there will be fragmented policy solutions that create additional and unnecessary risks and harms.” 

The article discusses the problems with addressing biometric systems and risks in isolation, for example, by focusing on a single modality such as face recognition or DNA or even on a particular use case. Instead, the article points out why it is essential to contextualize biometric systems in the broader context of all biometric modalities, and view biometrics as a complete ecosystem of multiple biometrics. The article then discusses the many administrative and procedural controls that are utilized in globally harmonized chemical safety regulations, and how that model could be adapted for a multi-biometric ecosystem. 

“The rich, adaptable, comprehensive, and yet granular chemical safety models in use today provide a pathway to move biometric regulation away from the fragmented and ineffective current practices that rely on consent, bans, and single-modality regulations. It is essential that complex biometric ecosystems are regulated consistently, comprehensively, and in a manner that is harmonized across jurisdictions so that biometrics are not subject to fragmentation that results in inconsistent or weak data governance, security, and privacy protections. Biometrics, as a technology of concern, merits high levels of attention to administrative and procedural controls, as well as a focus on harmonization on key aspects of regulation, such as agreement on definitions.”

WPF published early work in 2020 looking at how the structure of safety regulations could be adapted for the biometric context.. The article for Turkish Policy Quarterly takes on a fuller analysis of these ideas.