As Boyd explained at a conference in June, the key question for OBIM is, “If we pick up someone from Panama at the southern border at age four, say, and then pick them up at age six, are we going to recognize them?”

Facial recognition technology (FRT) has traditionally not been applied to children, largely because training data sets of real children’s faces are few and far between, and consist of either low-quality images drawn from the internet or small sample sizes with little diversity. Such limitations reflect the significant sensitivities regarding privacy and consent when it comes to minors. 

According to Syracuse University’s Transactional Records Access Clearinghouse (TRAC), 339,234 children arrived at the US-Mexico border in 2022, the last year for which numbers are currently available. Of those children, 150,000 were unaccompanied—the highest annual number on record. If the face prints of even 1% of those children were in OBIM’s craniofacial structural progression initiative, the resulting data set would dwarf nearly all existing data sets of real children’s faces used for aging research.

Prior to publication of this story Boyd told MIT Technology Review that to the best of his knowledge, the agency has not yet started collecting data under the program, but he adds that as “the senior executive,” he would “have to get with [his] staff to see.” He could only confirm that his office is “funding” it. Despite repeated requests, Boyd did not provide any additional information. After publication, DHS denied that it had plans to collect facial images from minors under 14. 

Boyd described recent “rulemaking” at “some DHS components,” or sub-offices, that have removed age restrictions on the collection of biometric data. US Customs and Border Protection (CBP), the US Transportation Security Administration, and US Immigration and Customs Enforcement declined to comment before publication. US Citizenship and Immigration Services (USCIS) did not respond to multiple requests for comment. OBIM referred MIT Technology Review back to DHS’s main press office. 

DHS did not comment on the program prior to publication, but sent an emailed statement afterwards: “The Department of Homeland Security uses various forms of technology to execute its mission, including some biometric capabilities. DHS ensures all technologies, regardless of type, are operated under the established authorities and within the scope of the law. We are committed to protecting the privacy, civil rights, and civil liberties of all individuals who may be subject to the technology we use to keep the nation safe and secure.”

The agency later noted “DHS does not collect facial images from minors under 14, and has no current plans to do so for either operational or research purposes,” walking back Boyd’s statements. 

Boyd spoke publicly about the plan in June at the Federal Identity Forum and Exposition, an annual identity management conference for federal employees and contractors. But close observers of DHS that we spoke with—including a former official, representatives of two influential lawmakers who have spoken out about the federal government’s use of surveillance technologies, and immigrants’ rights organizations that closely track policies affecting migrants—were unaware of any new policies allowing biometric data collection of children under 14.