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Consent DecreeHigh Risk

FTC Bans Rite Aid from AI Facial Recognition for 5 Years Over Biometric Harms

Rite AidDecember 19, 2023Federal Trade Commission

Summary

The FTC settled charges that Rite Aid deployed AI facial recognition technology in hundreds of stores from 2012 to 2020 without reasonable safeguards, resulting in false-positive matches that disproportionately harmed women and people of color. The proposed order bans Rite Aid from using facial recognition for surveillance for five years and requires comprehensive biometric data safeguards, data deletion, consumer notifications, and a certified security program.

Remedy

Rite Aid is banned from using facial recognition for surveillance for five years, must delete all collected biometric images and derived algorithms, provide clear notice to consumers about its use, notify consumers when actions are taken based on the system, implement a comprehensive data security program overseen by executives, obtain independent third-party security assessments, and provide annual CEO certifications.

BanInjunctionConsent DecreeData DeletionCorrective NoticeCompliance ProgramAudit RequirementReporting Requirements

Contract Impact

In-house legal teams should review all vendor agreements (especially with technology/AI providers), customer privacy policies, and any data processing agreements where biometric data or automated surveillance is involved. Specific clauses to scrutinize include: data processing specifications (particularly for biometric identifiers), consent mechanisms for surveillance, data retention and deletion schedules, breach notification protocols, audit rights, and representations/warranties regarding algorithmic fairness and accuracy. Given the FTC's order, contracts may need amendments to: (1) explicitly prohibit or restrict AI facial recognition for surveillance purposes, (2) mandate regular disparate impact assessments for automated systems, (3) require robust data minimization and deletion protocols for biometric data, (4) establish certified security programs aligned with FTC expectations, and (5) incorporate consumer notification requirements for false positives or data misuse. Teams should also assess termination rights if a vendor's technology poses uncorrectable consumer risks.

Contract Search Terms

biometric data clauseAI surveillance prohibitiondata deletion requirementconsumer notification clausesecurity program certificationfalse positive mitigationautomated decision-making systemdisparate impact assessmentdata processing addendumsensitive data handling

Laws Cited

FTC Act Section 52010 Commission data security order

Violation Types

Entity Details

Entity

Rite Aid

Industry

Retail

Official Sources

Source Evidence

Entity Name
"Rite Aid will be prohibited from using facial recognition technology for surveillance purposes for five years to settle Federal Trade Commission charges"
Violation Types
"the retailer failed to implement reasonable procedures and prevent harm to consumers in its use of facial recognition technology"
Violation Types
"facial recognition technology falsely flagged the consumers as matching someone who had previously been identified as a shoplifter"
Violation Types
"Rite Aid’s facial recognition technology was more likely to generate false positives in stores located in plurality-Black and Asian communities than in plurality-White communities"
Remedy Types
"Rite Aid will be prohibited from using facial recognition technology for surveillance purposes for five years"
Remedy Types
"Delete, and direct third parties to delete, any images or photos they collected because of Rite Aid’s facial recognition system"

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