Facial Recognition in Youth Sports: The Legal Risks Few Are Talking About

Youth Sports Safety & Integrity

Facial recognition technology is often promoted as a faster way to verify identity and streamline check-in. But when applied to minors, it introduces a very different category of legal exposure. Across the United States and internationally, biometric privacy laws, lawsuits, and enforcement actions have made one thing clear: collecting and storing facial data carries serious legal consequences — especially when children are involved.

Biometric Data Is Not Treated Like Regular Data

Facial recognition systems collect what is legally defined as biometric identifiers — data derived from a person’s unique biological characteristics. Unlike a password or an email address, biometric data cannot be changed if compromised.

Several states treat biometric identifiers as highly sensitive information requiring strict compliance standards. The most influential example is Illinois’ Biometric Information Privacy Act (BIPA), which allows private citizens to sue organizations directly for violations.

Under BIPA, organizations must:

  • Obtain written informed consent before collecting biometric data
  • Disclose retention and deletion policies
  • Securely store biometric information
  • Refrain from profiting from biometric data

Failure to comply has led to massive settlements involving major technology companies.

Major Settlements Show the Financial Risk

Biometric lawsuits are not theoretical. They have resulted in some of the largest privacy settlements in recent years.

  • Meta agreed to a $650 million settlement in Illinois over facial recognition tied to Facebook photo tagging.
  • TikTok agreed to a $92 million settlement related to biometric data collection claims.
  • Google agreed to a $100 million settlement involving facial grouping features in photo storage.
  • Snap Inc. agreed to a $35 million settlement connected to facial recognition filters.

These cases largely involved adult users. Introducing facial recognition into youth sports — where minors are involved — adds another layer of legal sensitivity.

State Enforcement Is Expanding

Illinois is not the only state enforcing biometric laws. Texas reached a $1.4 billion settlement with Meta in 2024 over alleged facial recognition violations under its biometric statute. California regulates biometric information under broader privacy frameworks that allow for enforcement and penalties.

The pattern is consistent: state governments are actively pursuing biometric compliance failures.

Federal Regulators Have Taken Action

The Federal Trade Commission (FTC) has also intervened in facial recognition cases. In 2021, the FTC ordered a company to delete improperly collected facial recognition data and algorithms developed from that data. The agency emphasized the importance of transparency, consent, and proper data handling.

When minors are involved, regulators historically apply even greater scrutiny under child privacy principles.

Schools Have Already Faced Resistance

Facial recognition in child-focused environments has triggered public and regulatory pushback. In 2019, a New York school district’s attempt to deploy facial recognition technology was blocked by the state education department pending further review. New York later imposed a temporary statewide moratorium on facial recognition in schools while risks were evaluated.

Other municipalities, including Portland, Oregon, enacted strong restrictions on private use of facial recognition technology in public spaces.

The concern was not convenience — it was long-term risk to minors’ privacy.

Why Youth Sports Faces Unique Exposure

Youth sports organizations operate in a particularly vulnerable legal category:

  • Minors cannot legally provide independent consent
  • Parents may not fully understand biometric mapping implications
  • Retention timelines often extend beyond a season or tournament
  • Biometric data cannot be “reset” if breached

Even if consent forms are signed, failure to follow precise statutory requirements can trigger class action exposure. Plaintiffs’ firms actively monitor biometric practices, particularly in states with private rights of action like Illinois.

Most Lawsuits Stem From Process Failures

Importantly, most biometric litigation does not involve malicious intent. It stems from procedural missteps:

  • Insufficient disclosure language
  • Improper retention schedules
  • Failure to obtain written consent correctly
  • Lack of clear deletion protocols

In youth environments, the margin for error narrows even further. Organizations may rely on third-party vendors for facial recognition services, but liability often extends to the entity collecting the data — not just the software provider.

The Strategic Question for Directors

Facial recognition may promise faster check-in and streamlined identity verification. But legal history shows that biometric collection carries long-term regulatory and litigation exposure.

Directors must ask:

Is marginal convenience worth the possibility of statutory damages, class action litigation, and reputational harm?

A Smarter Approach to Verification

Youth sports does not need to store biometric data to maintain competitive integrity. Secure, privacy-first verification models can confirm eligibility without collecting facial geometry or building biometric databases.

The organizations that lead the future of youth sports will prioritize:

  • Transparent data practices
  • Limited data collection
  • Clear deletion standards
  • No biometric storage of minors’ facial data

Technology should elevate youth sports — not introduce unnecessary legal risk.

 

If your organization is evaluating facial recognition or biometric tools for events, now is the time to fully understand the legal landscape. Learn how NSID provides secure age and grade verification without storing facial recognition data.

Visit National Sports ID to see how privacy-first verification protects your athletes and your organization.