Function Creep in Biometrics: Concerns and Real-World Examples

Biometric technologies—fingerprint scanners, facial recognition, and voiceprints—have become integral to modern life, promising enhanced security and convenience. However, a growing concern known as function creep threatens to undermine these benefits. Function creep occurs when biometric data, collected for a specific purpose, is repurposed for unrelated uses without transparency or consent.

Given the immutable nature of biometric data, such as your palm vein pattern or facial geometry, this expansion raises significant ethical, privacy, and security concerns. This article explores the mechanics of the function creep, why it’s a problem, and examines four real-world cases that illustrate its impact.

Function Creep in Biometrics: Concerns and Real-World Examples - featured Image

What Is Function Creep in Biometrics?

Function creep in biometrics refers to the gradual expansion of biometric data usage beyond its original purpose, often without user consent or transparency. For example, a fingerprint collected for workplace attendance might later be used for unrelated purposes like credit scoring or law enforcement surveillance.

Function creeping often starts innocently, driven by the desire to maximize the utility of existing data. Organizations may repurpose biometric databases to save costs or meet new demands, but this incremental expansion can erode user trust and autonomy. The permanence of biometric data amplifies the stakes—unlike a password, you can’t change your face or fingerprints if they’re compromised. Understanding this phenomenon is critical to addressing its risks.

Why Does Function Creeping Raise Serious Concerns?

The unauthorized expansion of biometric data use poses multiple risks, from individual privacy violations to broader societal harms. Below, we outline the primary concerns, combining narrative insights with structured points to highlight the stakes.

Erosion of Privacy

When biometric data is used beyond its original purpose, individuals lose control over their personal information. For example, a facial scan collected for a seemingly benign purpose, like unlocking a device, might later be shared with third parties for profiling or surveillance. This loss of agency undermines trust in institutions and technology providers.

Security Risks

Repurposing biometric data increases the value of databases as targets for cyberattacks. A breach in a multi-purpose biometric system could expose sensitive information across contexts—financial, governmental, or personal—leading to identity theft or worse.

Ethical Issues

Function creeping often bypasses ethical principles like informed consent and proportionality. Using biometric data for unanticipated purposes, such as targeting ads or tracking individuals, can exploit vulnerable populations, particularly in regions with weak regulatory oversight.

Function Creep - A 2021 study by the Pew Research Center found that 64% of Americans believe biometric data, such as facial recognition or fingerprints, is often used for purposes beyond what was originally disclosed.
64% of Americans think Function Creep is a common occurrence.

Why Is Regulation Lagging?

Many countries lack comprehensive laws governing biometric data, allowing function creeping to flourish. Without clear rules, organizations face little accountability for repurposing data, leaving users vulnerable.

Key concerns include:

  • Loss of Autonomy: Users are often unaware their biometric data is being repurposed, stripping them of control.
  • Risk of Discrimination: Expanded biometric use can enable profiling, disproportionately harming marginalized groups.
  • Erosion of Trust: Unintended data uses can undermine public confidence in biometric technologies and the entities deploying them.

Real-World Examples of Function Creeping in Biometrics?

To illustrate the tangible impacts of function creep, we examine four documented cases where biometric systems were extended beyond their original scope, highlighting the consequences and responses.

Clearview AI and Law Enforcement

Original Purpose

Clearview AI developed a facial recognition database by scraping billions of images from social media platforms, initially intended for limited security applications.

Creep Mechanism

The company shared this database with law enforcement agencies worldwide to identify individuals in criminal investigations, far beyond the original context of collection.

Impact

This unauthorized expansion sparked widespread criticism for violating privacy, as social media users were unaware their images were being used for surveillance.

Response

Clearview AI faced legal challenges, including fines in multiple jurisdictions for “illegal” data practices, prompting calls for stricter facial recognition regulations.

Aadhaar in India

Original Purpose

India’s Aadhaar program, the world’s largest biometric ID system, collects fingerprints and iris scans to provide a unique ID for accessing government services like welfare distribution.

Creep Mechanism

Private companies and government agencies have accessed Aadhaar data for unrelated purposes, such as verifying customers for banking or telecom services, often without clear consent.

Impact

Alleged data leaks and unauthorized access raised concerns about privacy and security, with critics warning of surveillance and exploitation risks in this massive database.

Response

Legal challenges and public advocacy groups have pushed for stronger data protection laws in India, though regulatory gaps persist.

7-Eleven’s Retail Surveillance in Australia

Original Purpose

In 2021, 7-Eleven stores in Australia implemented facial recognition to monitor customers for security and loss prevention.

Creep Mechanism

The collected biometric data was also used to build demographic profiles for marketing purposes without customer consent.

Impact

This revelation led to public outcry and regulatory scrutiny, as customers were unaware their biometric data was being repurposed.

Response

Australia’s privacy regulator investigated, and 7-Eleven faced pressure to revise its data practices, highlighting the need for transparency in retail surveillance.

Google’s Biometric Data Practices

Original Purpose

Google collects biometric identifiers, such as voiceprints and facial geometry, through products like Google Photos and Google Assistant for user authentication and functionality.

Creep Mechanism

In 2025, Texas Attorney General Ken Paxton accused Google of using this data to enhance AI models and profile users beyond the initial scope, without adequate consent.

Impact

These allegations raised concerns about function creep in consumer tech, as users were unaware their biometric data was being repurposed for AI training or advertising.

Response

The lawsuit prompted calls for clearer data usage policies, though global standards for biometric data in tech remain inconsistent.

How Can We Mitigate Function Creeping?

Addressing function creeping requires proactive measures to balance innovation with ethical responsibility. Below, we outline strategies to curb its risks, blending narrative and actionable steps.

Strengthening Regulation

Governments must enact clear laws limiting biometric data use, mandating transparency, and enforcing penalties. The EU’s GDPR offers a model, though more specific biometric regulations are needed to address function creeping.

Enhancing User Consent

Organizations should implement robust consent mechanisms, ensuring users are informed about data uses and can opt out. User-friendly interfaces that explain data purposes before collection can empower individuals to make informed choices.

Implementing Technical Safeguards

To prevent unauthorized repurposing, organizations can adopt:

  • Data Minimization: Collect only the biometric data necessary for the intended purpose.
  • Encryption and Anonymization: Secure data to prevent misuse, even in a breach.
  • Purpose Limitation: Design systems with technical barriers, like siloed databases and restrict data to its original intent.

Raising Public Awareness

Educating users about function creep empowers them to demand accountability. Public campaigns and media coverage can highlight risks and encourage scrutiny of biometric data practices.

These solutions face challenges, including resistance from organizations prioritizing efficiency and the slow pace of global regulatory alignment. However, they are essential to protect users in an era of expanding biometric use. 

Why Must We Stay Vigilant?

A function creep in biometrics is a pressing issue that threatens privacy, security, and trust in a world increasingly reliant on these technologies. The cases of Clearview AI, Aadhaar, 7-Eleven, and Google illustrate how biometric data, collected for specific purposes, can be repurposed in ways that erode individual autonomy and expose users to risks. By strengthening regulations, enhancing consent, implementing technical safeguards, and raising awareness, we can mitigate these dangers. As biometric systems continue to evolve, staying vigilant ensures that their benefits—security and convenience—do not come at the cost of our fundamental rights.