Practical Compliance Tips: New York City “Commercial Establishments” Biometric Privacy Law
New York City (“NYC”) has quickly become one of the newest hotbeds of biometric privacy legislative activity, having enacted several laws since the start of 2021 that directly govern the collection and use of biometric data.
In addition to the New York City Tenant Data Privacy Act (“TDPA”), which regulates the use of biometric data by owners and operators of “smart access buildings,” New York City Council also enacted the nation’s first municipal-level biometric privacy law regulating “commercial establishments” (the “NYC Biometrics Ordinance”), which went into effect on July 9, 2021.
Because the NYC Biometrics Ordinance will almost certainly not be the last of its kind, commercial establishments that utilize biometric data in their business operations—even those located beyond the borders of the Big Apple—should take proactive steps to implement robust biometric privacy compliance programs to ensure continued compliance with current and anticipated biometrics laws to mitigate potential liability exposure.
To read the full blog post, please visit our Biometric Privacy Insider blog.