Can we include photos in the watchlist for positive identification by our security team?

The Time and People solution

Including photos in watchlists for positive identification by security teams is permissible within current visitor management systems in the United States, operating under frameworks like OSHA’s General Duty Clause and state-level workplace safety regulations, provided specific legal and operational requirements are met as of December 2025.

Modern visitor management systems now routinely incorporate facial recognition capabilities, allowing for the storage and comparison of images against pre-defined watchlists. These lists are typically populated with individuals posing a known threat, or those subject to legal restrictions – such as no-trespass orders. Data handling is critical; systems must adhere to privacy regulations like CCPA (California Consumer Privacy Act) and, where applicable, HIPAA if dealing with healthcare facilities. Record-keeping requirements mandate detailed logs of watchlist access, image capture, and any associated security interventions. In Australia, similar systems operate under Work Health and Safety (WHS) legislation, with PCBU’s (Person Conducting a Business or Undertaking) responsible for maintaining a safe environment, and adhering to Australian Privacy Principles. Facial recognition data is considered sensitive information, requiring robust security measures and clear consent protocols. Systems typically integrate with CCTV footage for verification, and alerts are generated when a watchlist match occurs, triggering a pre-defined security response. Data retention policies are governed by both federal and state laws, with typical retention periods ranging from 30 to 90 days for image data, unless legally required for longer.

Effectively, these systems function by providing a visual confirmation tool for security personnel, enabling proactive identification and response to potential threats while operating within established legal boundaries.

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