Privacy & Information Security Law Blog

On December 31, 2022, Baltimore’s ordinance banning the private sector’s use of facial recognition technology expired. The ordinance, which was enacted in 2021, banned private entities and individuals within the city limits from using facial recognition technology, including obtaining, retaining, accessing or using a “face surveillance system” or any information obtained from such system. The Baltimore ordinance followed a similar ban on the use of facial recognition technology by private sector companies in Portland, Oregon, enacted in 2020. New York City also passed an ordinance in 2021 regulating commercial establishments’ use of biometric technology.

The Baltimore ordinance included a sunset provision to automatically expire at the end of 2022. Baltimore’s City Council did not take action to maintain this ordinance prior to the sunset date, allowing the ordinance to expire.

Read our earlier posts for more details about the Baltimore, Portland and New York City biometrics ordinances.