Ryanair facial recognition customer verification

Occurred: July 2023

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The use of live facial recognition during Ireland-based budget airline Ryanair's external online booking process to verify the identities of its customers has been labelled 'invasive' and 'unjustified' in a legal complaint (pdf) made by privacy group NYOB. 

The complaint, which was lodged in Spain in the name of Spanish customer, alleges that Ryanair failed to provide customers with informed or 'comprehensible information about the purpose' of the process, and that it is illegal under the EU's General Data Protection Regulation (GDPR).

Ryanair defended the system as necessary due to third-party sellers miss-selling flights, providing incorrect contact details, or hiking up fares. 

'Ryanair has no commercial relationship with any OTA nor are they authorised to sell our flights. OTAs scrape Ryanair’s inventory and in many cases miss-sell our flights and ancillary services. As a result, and in order to protect customers, any customers who book through an OTA are required to complete a simple customer verification process,' it explained. 

Operator: Ryanair

Country: Spain; EU

Sector: Aerospace

Purpose: Verify customer identity

Technology: Facial recognition; Computer vision; Machine learning
Issue: Privacy

Transparency: Privacy