Appearance Recognition Guides
TOC Links:
Appearance Recognition Compliance Guide
Appearance Recognition in BluSKY (Short Version)
Appearance Recognition in BluSKY (Standard Form)
Appearance Recognition in BluSKY (Technical Form)
Where BluSKY Person Recognition May Not be Accepted
Appearance Recognition Compliance Guide
BluSKY Person Reader Deployments Across the U.S.
BluSKY’s appearance recognition is safe, private, and opt-in. Still, some cities and states have adopted rules that limit or condition how face recognition can be used. This page summarizes those rules so that customers and integrators know where BluSKY’s approach is accepted, where conditions apply, and where recognition must be disabled.
Quick Reference Matrix
Jurisdiction |
Status for Private Facilities |
Key Rules / Conditions |
BluSKY Compliance Guidance |
Portland, OR (City) |
Prohibited in places of public accommodation |
City ban on private-sector face recognition in retail, lobbies, public spaces |
Disable appearance recognition in public-facing areas; rely on card/phone/QR/PIN; proof-of-presence photos OK |
San Francisco, CA (City) |
Allowed |
Ban applies only to government use |
No restrictions on private buildings |
Boston, MA (City) |
Allowed |
Government ban only |
Safe to use in private facilities |
Minneapolis, MN (City) |
Allowed |
Government ban only |
Safe to use in private facilities |
Portland, ME (City) |
Allowed |
Government ban only |
Safe to use in private facilities |
New York City, NY (City) |
Allowed with conditions |
Retail/food/entertainment: must post biometric notice, no sale/trade of data. Residential smart access: explicit consent, data minimization, retention limits |
Post signage, follow NYC TDPA consent & retention rules. BluSKY opt-in/opt-out matches requirements |
Baltimore, MD (City) |
Allowed |
Private ban expired Dec 2022 |
No current restrictions |
Illinois (State) |
Allowed with conditions |
BIPA: written consent, retention schedule, delete after purpose or 3 years, private right of action |
Capture explicit opt-in consent; publish retention/deletion policy; leverage BluSKY’s opt-in/opt-out |
Texas (State) |
Allowed with conditions |
CUBI: notify + obtain consent before capture; confidentiality + destruction |
Inform and obtain consent before enrollment; configure automatic deletion policies |
Washington State |
Allowed with conditions |
RCW 19.375: notice, consent or opt-out mechanism, disclosure & retention limits |
BluSKY’s consent/opt-out aligns; ensure disclosure of retention/deletion |
Maryland (State) |
Allowed with conditions |
Employers must get consent before using face recognition in interviews (HB1202) |
Restriction applies to hiring only, not access control |
Maine (State) |
Allowed |
State ban applies only to government |
No restrictions on private facilities |
Key Takeaways
Only one “hard stop”: Portland, OR. Face recognition cannot be used in private-sector places of public accommodation.
- Government-only bans (e.g., SF, Boston, Minneapolis, Portland ME) do not affect private deployments.
- Consent-focused states (IL, TX, WA, NY): BluSKY’s on-reader opt-in/opt-out and “no biometric measurements stored” approach is well aligned. Just ensure signage, consent logs, and retention schedules are in place.
- Proof-of-presence photos are not biometric templates. They are event logs and generally outside the scope of these bans, but best practice is to disclose their use in local privacy policies.
BluSKY Recommended Practice
- Enable on-reader opt-in/opt-out everywhere – satisfies consent requirements and empowers individuals.
- Deploy signage where required (e.g., NYC commercial spaces).
- Publish data retention & deletion policies – follow stricter state rules (IL/TX/WA) as your baseline.
- Disable appearance recognition in public-facing areas in Portland, OR.
✅ Bottom line: With BluSKY, compliance is straightforward: only Portland, OR requires disabling appearance recognition; elsewhere, BluSKY’s opt-in design and dynamic, non-biometric storage approach put you ahead of legal requirements.
Appearance Recognition in BluSKY (Short Version)
Appearance Recognition in BluSKY - Safe · Private · Your Choice
What It Is
- Appearance recognition lets you use your face for fast, secure access.
- It works alongside your card, phone, PIN, or QR code.
- Enrollment happens instantly—no extra steps needed.
What We Store
- A proof-of-presence photo is captured at entry, just like a badge swipe photo.
- This photo links the person at the door with the access event.
- BluSKY does not store biometric measurements (like eye distances or face blueprints). Instead, your face is converted into a secure, meaningless code used only inside the system.
Your Control
- Opt in or opt out at any time—just present your card and tell the reader your choice.
- Use your face alone or combine it with your card, phone, or PIN.
- You decide what’s most comfortable for you.
Why Use It?
- No fumbling for your badge or phone.
- Instant recognition and entry.
- Safe, private, and completely under your control.
✅ Bottom line: BluSKY appearance recognition is convenient, secure, and respects your privacy. It’s always your choice—and it makes access easier than ever.
Appearance Recognition in BluSKY (Standard Form)
Appearance Recognition in BluSKY - Safe · Private · Your Choice
At BluB0X, your privacy and security are our top priorities. Our appearance recognition technology in BluSKY is designed to make access safer and more convenient—while keeping you fully in control of how it’s used.
Proof of Presence vs. Biometric Data
Like many modern security systems, BluSKY captures a proof-of-presence photo when someone uses a Person Reader. This is part of the security protocol:
- It shows who was physically present at the moment of entry.
- It links the photo to the access event (badge swipe, phone credential, QR code, PIN, or face recognition).
- It allows security teams to detect if someone is using a badge or credential that does not match the person presenting it.
- What BluSKY does not do: we do not store or use face measurements—like the distance between your eyes, or a “blueprint” of your face—that could be reverse-engineered. Instead, appearance recognition works by converting your image into a secure, dynamic code that has no meaning outside the system.
You’re in Control
Every individual decides for themselves whether to use appearance recognition.
- Opt in or out at any time: Simply present your credential at a Person Reader and say you’d like to use your face—or not use it.
- Use it your way: You can choose appearance recognition by itself or in combination with your other credentials, like a card, phone, QR code, or PIN.
- Your comfort level matters: If you prefer to use only your card or phone, you can do that. If you want the convenience of face-based check-in, that’s available too.
Why People Choose It
Opting into appearance recognition makes access and check-in fast, seamless, and secure.
- No fumbling for your badge or phone.
- Instant recognition at any Person Reader.
- Enrollment happens automatically—nothing extra to do.
- It’s safe, private, and completely your choice.
✅ Bottom line: BluSKY’s appearance recognition provides the convenience of using your face as your identity, without the privacy risks of traditional biometrics. You remain in control, your data cannot be reverse-engineered, and proof-of-presence photos serve only as part of the building or facility’s security protocol.
Appearance Recognition in BluSKY (Technical Form)
Appearance Recognition in BluSKY - Safe · Private · Your Choice
At BluB0X, we believe appearance recognition should be both private and convenient. That’s why BluSKY uses the most modern technology available to recognize you—while keeping your identity fully in your control.
BluSKY’s appearance recognition is different from traditional biometrics, why it is safer, and why you can feel comfortable choosing it.
Traditional Biometrics: Fixed and Risky
Traditional biometrics work by extracting fixed, human-engineered measurements:
- Fingerprints: ridges and bifurcations are mapped.
- Iris scans: patterns of rings and crypts are stored.
- Early facial recognition: distances between eyes, nose, jawline, and other geometry were captured.
These systems then stored a template of your body that is:
- Fixed for life (you can’t change your iris or fingerprint).
- Directly tied to your physical traits, making it easy to link back to you.
- Vulnerable: if stolen, you cannot “reset” your face or fingerprint the way you reset a password.
This raised major privacy concerns. Once exposed, your biometric identity could never be made private again.
Modern Appearance Recognition: A New Approach
BluSKY’s Person Readers don’t rely on static, hand-crafted measurements. Instead, they use neural networks to create what’s called an embedding:
- An embedding is a mathematical representation of your face in high-dimensional space (think hundreds of numbers).
- These numbers are not eye distances, not nose widths, not jawline angles—they have no human meaning.
- They exist only to allow the system to separate one person from another in a safe, consistent way.
Even more important:
- Embeddings cannot be reverse-engineered into a usable face. At best, researchers can produce blurry, generic likenesses that don’t reveal who you are.
- They are dynamic—as models are retrained and improved, the codes evolve. Unlike a fingerprint template, they don’t last forever.
- They are system-specific—your embedding only works inside BluSKY, with BluSKY’s models. Outside the system, it’s just random numbers.
Proof-of-Presence: Security Without Exposure
Like many security systems, BluSKY also captures a proof-of-presence photo whenever you use a Person Reader.
- This photo links the event to the person physically present.
- It ensures no one is using a badge or credential that belongs to someone else.
- It is used only for auditing and security—not for building a biometric template.
This is fundamentally different from storing biometric measurements. A proof-of-presence photo is like a time-stamped record in the security log, not a reusable “key” to your identity.
Control Is Always Yours
We’ve built BluSKY so that you always decide:
- Opt in or out anytime: Present your credential and tell the Person Reader your preference.
- Combine credentials: Use appearance recognition by itself, or pair it with a card, phone, QR code, or PIN for added security.
- Comfort first: If you’d rather not use appearance recognition, simply opt out—you can still use your other credentials.
Why This Is Safer Than Traditional Biometrics
- No permanent templates: Unlike fingerprints or iris codes, BluSKY’s embeddings are dynamic and refreshable.
- No human-readable data: The system stores numbers, not measurements that can map back to your physical body.
- Non-reversible: No one can reconstruct your face or identity from BluSKY’s stored codes.
- Proof-of-presence only: Photos are used for event auditing, not as biometric templates.
- Full user control: Opt in or out at any moment.
Convenience Without Compromise
With BluSKY appearance recognition, you get the best of both worlds:
- Fast, hands-free access without badges or phones.
- Security backed by proof-of-presence photos.
- Privacy by design, with no biometric measurements stored.
✅ Bottom line: BluSKY appearance recognition is not traditional biometrics. It’s a modern, safe, privacy-conscious system that puts control in your hands. You’re not giving away your identity—you’re simply choosing the most convenient way to prove it.
Where BluSKY Person Recognition May Not be Accepted
Portland, OR (citywide private-sector ban in public accommodations).
- Private entities may not use “Face Recognition Technologies” in any place of public accommodation (retail, lobbies open to the public, etc.). Limited exceptions (e.g., unlocking your own device). Statutory damages are $1,000 per day per violation. This is the one city where a BluSKY Person Reader using face recognition in a publicly accessible area would generally be disallowed. (Portland.gov)
Cities with government-only bans
These ordinances restrict city departments/police, not private property owners/operators:
- San Francisco, CA – Government ban; private use not covered. (Davis Wright Tremaine, San Francisco Police Department)
- Boston, MA – Government ban. (Electronic Frontier Foundation, WBUR)
- Minneapolis, MN – Government ban (police/city agencies). (lims.minneapolismn.gov, GovTech)
- Portland, ME – Government ban; later strengthened by voter initiative. (ACLU of Maine, Epic Privacy, Electronic Frontier Foundation)
Bottom line for these: BluSKY Person Readers in private facilities are generally permissible, but deployments in city-owned buildings (or with city agencies as customers) could be restricted.
Cities where it’s allowed but conditioned
New York City, NY
- Commercial establishments (retail/food/entertainment) must post a biometric notice and may not sell/trade biometric identifier information (Local Law 3 of 2021 + DCWP rule). (intro.nyc, rules.cityofnewyork.us)
- Residential “smart access” (multifamily): the Tenant Data Privacy Law requires express consent, strict data-minimization/retention limits, and prescribes disclosures—very compatible with BluSKY’s on-reader opt-in/opt-out and limited data approach. (NYC Government, Hunton Andrews Kurth, nylaborandemploymentlaw.com)
Notable recent change
Baltimore, MD
- A 2021 law temporarily banned private use of facial recognition, but it included a sunset and expired Dec. 31, 2022. Private deployments are currently permitted (subject to any state/federal rules). (SHRM, Hunton Andrews Kurth)
State laws that affect city deployments
(Not bans—but high-stakes consent/retention rules. These apply anywhere in the state, including big cities.)
- Illinois (BIPA) – Written consent, public retention schedule, deletion after purpose or 3 years after last interaction, private right of action (heavy litigation). If you deploy in Chicago or elsewhere in IL, make sure your BluSKY flow captures explicit consent and your policy is published. (Note: penalties were moderated in 2024 but compliance remains crucial.) (Illinois General Assembly, Illinois General Assembly, Reuters)
- Texas (CUBI) – Inform before capture and obtain consent for “record of hand or face geometry”; confidentiality and destruction duties. Relevant in Dallas/Austin/Houston and statewide. (Texas Statutes, Texas Attorney General, Justia)
- Washington State (RCW 19.375) – Notice + consent or opt-out mechanism, disclosure/retention limits for commercial enrollment. Relevant in Seattle and statewide. (Washington Legislative Information, Justia)
- Maine (statewide) – Strong government restrictions; does not ban private use. (Portland, ME’s city rule is government-only as noted above.) (American Civil Liberties Union)
- Maryland (HB1202) – Narrow rule: employers need applicant consent to use facial recognition during interviews (not an access-control ban, but good to know for on-site recruiting). (Maryland General Assembly)
What this means for BluSKY Person Recognition
- Hard stop: Public-facing deployments in Portland, OR (retail, publicly accessible lobbies) should disable facial recognition features and rely on card/phone/QR/PIN only; proof-of-presence photos are not the issue—the recognition is. (Portland.gov)
- NYC retail/food/entertainment: Post the biometric notice; do not sell biometric info. NYC residential: capture explicit opt-in, follow TDPA data limits/retention. (intro.nyc, rules.cityofnewyork.us, NYC Government)
- IL/TX/WA: Bake consent + retention + deletion into your BluSKY flows and BluINFO policy pages; your on-reader opt-in/opt-out and “no face-measurement templates” stance align well with these regimes. (Illinois General Assembly, Texas Statutes, Washington Legislative Information)