On the same day DHS confirmed nationwide biometric exit photography, civil-liberties groups launched #FacesNotRequired, a coordinated media and legal campaign arguing the rule violates constitutional privacy rights. Defense technology site SSBCrack News detailed the campaign’s opening salvo on October 25, 2025, noting planned Freedom of Information Act requests and a petition for review in the D.C. Circuit.
The coalition—led by the Electronic Frontier Foundation, the American Civil Liberties Union and the Canadian-U.S. cross-border group OpenMedia—contends that capturing images of lawful permanent residents exceeds DHS’s statutory mandate and creates a de-facto travel dossier vulnerable to data breaches. They point to a 2023 CBP subcontractor hack that exposed 184,000 traveler photos as evidence of inadequate safeguards.
Business-travel associations are taking a nuanced stance. The Global Business Travel Association applauded a unified exit system that could speed Trusted Traveler enrollments but urged DHS to publish clear redress procedures and retention timelines. Airlines, for their part, worry about hardware costs, although DHS promises grant funding for initial installations.
For multinational employers, the dispute signals potential litigation-driven delays. Should courts grant a stay, carriers may adopt a patchwork of biometric practices, complicating duty-of-care planning. Mobility leaders should watch for airport-specific rollouts and incorporate privacy briefings into pre-travel orientations.
The coalition—led by the Electronic Frontier Foundation, the American Civil Liberties Union and the Canadian-U.S. cross-border group OpenMedia—contends that capturing images of lawful permanent residents exceeds DHS’s statutory mandate and creates a de-facto travel dossier vulnerable to data breaches. They point to a 2023 CBP subcontractor hack that exposed 184,000 traveler photos as evidence of inadequate safeguards.
Business-travel associations are taking a nuanced stance. The Global Business Travel Association applauded a unified exit system that could speed Trusted Traveler enrollments but urged DHS to publish clear redress procedures and retention timelines. Airlines, for their part, worry about hardware costs, although DHS promises grant funding for initial installations.
For multinational employers, the dispute signals potential litigation-driven delays. Should courts grant a stay, carriers may adopt a patchwork of biometric practices, complicating duty-of-care planning. Mobility leaders should watch for airport-specific rollouts and incorporate privacy briefings into pre-travel orientations.
