Beyond Fingerprints: Navigating The Biometric Amendment To The Colorado Privacy Act

On July 1, 2025, the Biometric Data Privacy Amendment to the Colorado Privacy Act will take effect, creating a new, stand-alone set of obligations for any entity—whether or not it is otherwise subject to the consumer-facing portions of the Colorado Privacy Act—that collects, captures, purchases, receives, or otherwise obtains "biometric identifiers" or "biometric data" from individuals in Colorado. See C.R.S. § 6-1-1314

Quick Hits

• Starting July 1, 2025, the Biometric Data Privacy Amendment to the Colorado Privacy Act will impose new obligations on entities collecting biometric data from individuals in Colorado, including employees and job applicants.
• The amendment introduces a consent paradigm limiting when employers can require biometric data, allowing mandatory consent only for specific purposes like secure access and workplace safety.