Incident 254: Google’s Face Grouping Allegedly Collected and Analyzed Users’ Facial Structure without Consent, Violated BIPA

Description: A class-action lawsuit alleged Google failing to provide notice, obtain informed written consent, or publish data retention policies about the collection, storage, and analysis of its face-grouping feature in Google Photos, which violated Illinois Biometric Information Privacy Act (BIPA).


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Alleged: Google developed and deployed an AI system, which harmed Google Photos users residing in Illinois , Google Photos users and Illinois residents.

Incident Stats

Incident ID
Report Count
Incident Date
Khoa Lam

GMF Taxonomy Classifications

Taxonomy Details

Known AI Goal

Data Grouping

Potential AI Technology

Clustering, Face Detection

Potential AI Technical Failure

Unauthorized Data


A "variant" is an incident that shares the same causative factors, produces similar harms, and involves the same intelligent systems as a known AI incident. Rather than index variants as entirely separate incidents, we list variations of incidents under the first similar incident submitted to the database. Unlike other submission types to the incident database, variants are not required to have reporting in evidence external to the Incident Database. Learn more from the research paper.