Schwab Vendor Exempt From Ill. Biometric Law, 7th Circ. Says - Law360
The 7th Circuit ruled that a Schwab vendor is exempt from the Illinois Biometric Information Privacy Act (BIPA), potentially limiting BIPA's scope for certain vendors.
Aforeworn detected this change in the US State Data-Privacy Laws space on August 29, 2026 and published this briefing so affected operators are forewarned rather than caught off guard. It is rated Medium urgency. Businesses using vendors for biometric data processing in Illinois, especially those in financial services, and privacy consultants advising them. should confirm how it applies to their specific situation before acting. There is a time constraint attached: No specific deadline provided.. Acting after that point can mean penalties, a lapsed licence, or lost eligibility — exactly the kind of surprise Aforeworn exists to prevent. Aforeworn monitors US State Data-Privacy Laws continuously and turns every detected change into a plain-English briefing like this one, so you always know first. Forewarned is forearmed.
What changed
A federal appellate court held that a vendor providing services to Schwab is exempt from BIPA, possibly because it is not a 'private entity' under the statute or due to the nature of its services.
Who it affects
Businesses using vendors for biometric data processing in Illinois, especially those in financial services, and privacy consultants advising them.
What you must do
Review vendor contracts and BIPA compliance programs to assess whether similar exemptions apply to your vendors.
Deadline
No specific deadline provided.
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