Portland Oregon Facial Recognition Law

The purpose of the Portland Oregon Facial Recognition Law ("34-10") is to "Prohibit the use of Face Recognition Technologies in Places of Public Accommodation by Private Entities within the boundaries of the City of Portland". You can read the full text of 34-10 in the Portland City Code.

Importantly, the definition of a "Place of Public Accomodation" includes:

"Any place or service offering to the public accommodations, advantages, facilities, or privileges whether in the nature of goods, services, lodgings, amusements, transportation or otherwise."

and excludes:

"An institution, bona fide club, private residence, or place of accommodation that is in its nature distinctly private."

This definition seems to allow the use of facial recognition for employee attendance and access control systems, such as NoahFace, provided they are used in employee only areas that are not open to the public.

Nonetheless, you should seek your own independent and professional legal advice on the interpretation of 34-10. Should you choose to take a conservative view and not use facial recognition at all, you can use NoahFace kiosks with non-biometric identification, such as with passcodes or QR codes, or use NoahFace Go on personal mobile devices. These options are explained below.

Kiosk Identification


NoahFace allows you to configure your access rules to require identification by passcode. Each employee is issued a unique 6 digit passcode. They simply enter this passcode each time they use NoahFace at a kiosk.

QR Codes

NoahFace allows you to configure your access rules to require identification by QR code. Each employees is issued an employee badge that displays a QR code of their employee number. They simply present their badge each time they use NoahFace at a kiosk.

Mobile Identification

NoahFace can be used on personal iOS and Android devices. Each employee is issued with an activation link, which they click on after they have installed the NoahFace Go App on their device. Once installed, they simply open the App to record their work times.

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