Global Mobility Lawyer: DHS proposes sweeping expansion of biometric data collection

Partner Blake Chisam provides insight to The Global Mobility Lawyer on the US Department of Homeland Security’s proposed regulation that would significantly broaden biometric data collection and continuous screening across the US immigration system.

The rule, published in the Federal Register on November 3, 2025, would authorize continuous vetting of foreign nationals, extend biometric requirements to US citizens involved in immigration filings, and broaden the range of data collected—including facial and voice recognition, iris scans and partial DNA profiles.

Blake notes that the proposal “marks a structural shift from transactional identity checks to continuous identity management,” cautioning that it expands the volume and sensitivity of data employers must manage. He advises global mobility teams to update privacy notices, vendor contracts and data-handling protocols to prepare for potential regulatory changes.

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