We published a new paper through OIX this week, titled Biometric Boarding using Identity as a Service: The potential impact on liability in the aviation industry. As the name suggests, we’re taken a deep dive into the thorny issues of identity and liability, together with the project partners British Airways and International Airlines Group (IAG), the U.S. Customs and Border Protection agency (CBP) and the International Air Transport Association (IATA).

The catalyst for the paper has been the recent trials taking place on a number of British Airways flights departing from Orlando and LAX airports, flying to the UK.  These trials have been testing the deployment of a new biometric boarding solution being rolled out by CBP, called the Traveler Verification Service, or TVS.

Under the new system, rather than an airline member of staff visually and manually checking each passenger’s passport and boarding pass immediately prior to boarding the aircraft, TVS instead operates an automated biometric gate.

The gate takes a facial image of the passenger, and then seeks to verify this by comparing it to a gallery of facial images of expected passengers.  The images in the gallery are selected from those that have been previously verified against an individual’s passport (typically this would take place the first time the passenger entered the United States, or when a US citizen applied for a passport).

If a suitable match can be found, to a high level of confidence, and the passenger is matched to appropriate biographical information in the system (a visa, for example), the gate opens, and the passenger passes through. If the passenger cannot be verified, the gate remains closed and they are processed manually by airline staff, as currently takes place.

Now, for someone like me that is obsessed about the future and new technology, the idea that the system can verify me simply via a photo, almost immediately, and with high level of confidence is hugely exciting – real futures stuff!

In practice, the speed and accuracy of the TVS system could significantly reduce false identifications and speed up boarding of the aircraft – a real win-win, for passengers, and airlines.  A biometric check can also provide a more accurate record of who is entering and leaving a country – this is after all the reason TVS has been introduced by CBP in the first place.

But the devil as ever is in the detail, as far as liability is concerned…

The existing processes that have been developed to check a passenger’s identity, and that they have a valid passport in their possession, are designed to ensure the airline is able to meet its legal responsibilities.  There are a number of scenarios (explored in detail in the report) where an airline may be held liable and fined if a problem comes to light upon arrival at their destination – for example if an airline has mis-identified a passenger or allows them to travel without the correct identification.

The report digs deep into the existing responsibilities that the airline has, and how these are enshrined in a series of bilateral MOUs between each airline and individual national governments.  Under the new system of biometric checks, when an airline effectively loses the ability to undertake its own checks, there is a question of whether responsibilities and liabilities should alter to align to the new system.

Indeed, the report asks, if governments are increasingly operators of identity management schemes, upon which other governments then (in practice) rely upon, should the future rules relating to liability be discussed not only bilaterally, but across multiple governments and airlines?


Ewan Willars, Innovate Identity