Passenger data
Who keeps your passport and biometric data at the airport
Several bodies hold your data. The airline keeps your booking and copies passport details at check-in 2,1. It passes them to border authorities, often through a government router 1. Airports may keep face templates if you use biometric boarding 3. Border agencies keep entry records and biometrics for set periods, from 48 hours for EU API data to 75 years for some US records of non-citizens 1,5. In the EU and UK you can ask each body for a copy of your data 9,11.
Your data passes through several hands
A single trip can put your passport data in four or more places. The airline holds your booking in its reservation system 2. At check-in it reads your passport and builds an advance passenger information (API) record. In the EU, carriers must read the machine-readable zone by automated means 1. The airline sends API and booking data (PNR) to the destination government 1,14.
The airport may run its own systems, such as face scans at security, bag drop or boarding gates. The European Data Protection Board (EDPB) looked at these uses in Opinion 11/2024, adopted on 23 May 2024 3. Border agencies capture data at passport control. The US, for example, photographs travellers at entry 4, and the EU Entry/Exit System records fingerprints and face images of non-EU visitors 6.
Contractors often run the technology. Under the EU General Data Protection Regulation (GDPR), a contractor acting for an airline or airport is a processor. It may handle the data only on documented instructions from the controller and under a binding contract 10.
| Who | What they typically hold | Example rule |
|---|---|---|
| Airline | Booking (PNR), passport details (API), boarding records | EU carriers delete API 48 hours after the router receives it, or keep them longer for normal business where other law allows 1 |
| Airport operator | Face templates for biometric checkpoints, where offered | EDPB says storage under the passenger's control can comply with GDPR, airport-controlled databases as described cannot 3 |
| Border agency | Entry and exit records, photos, fingerprints, API and PNR | EU Entry/Exit System keeps most records for three years 7 |
| Passenger Information Unit | PNR from airlines | EU PNR Directive: five years, masked after six months 14 |
| Contractor | Whatever the controller instructs | GDPR Article 28 contract and instructions 10 |
What the airline keeps
IATA says airlines collect PNR for their own business. The record holds data given at booking and stays in the reservation system until check-in 2. IATA notes that PNR accuracy is not guaranteed and that it can contain sensitive data 2.
API is narrower. Under EU Regulation 2025/12 it covers name, date of birth, sex, nationality, document type, number, issuing country and expiry, plus the booking locator, seat and baggage details where available 1. Biometric data is excluded 1. Carriers must store API for 48 hours after the router receives it, then delete it. They may keep data longer for normal business use where other law allows 1.
What the airport keeps when you use your face
Some airports and airlines let you pass security, bag drop, lounges or boarding by face scan. The EDPB tested four storage models 3.
In the first, the face template stays only on your own device. In the second, the airport holds it in encrypted form and only you hold the key. The EDPB said both could in principle comply with GDPR, with safeguards 3. In the third, the airport holds templates in a central database it controls. In the fourth, an airline or cloud provider holds them, possibly for as long as you keep an account. The EDPB said these two models, as described, cannot comply with GDPR data protection by design 3.
The opinion has limits. It does not cover border control or law enforcement use. It does not rule on the legal basis or the validity of consent 3. It urges the shortest possible retention period 3.
What border agencies keep, and for how long
Border agencies keep the longest records. In the EU, border authorities must delete API data 48 hours after receipt. They may keep data on passengers who did not reach a border crossing point for up to 48 more hours 1. PNR is kept by Passenger Information Units for five years under the EU PNR Directive, masked after six months 14. The EU Court of Justice ruled in 2022 that keeping all passengers' PNR beyond six months goes too far without objective evidence of a link to terrorism or serious crime 15.
The EU Entry/Exit System, run by eu-LISA, records name, travel document data, fingerprints, face images and the date and place of each entry and exit for non-EU visitors 6. It began a gradual launch on 12 October 2025 and replaced passport stamping on 10 April 2026 6. Its founding regulation sets three years for most records and refusals of entry. It sets five years for people who overstayed 7.
In the US, CBP keeps photos of US citizens for no more than 12 hours after identity checks. US citizens can opt out and ask for a manual document check 4. Non-citizens are enrolled in the DHS biometric database IDENT 4. Under a rule finalised in October 2025 and effective from 26 December 2025, CBP may photograph non-citizens at all entry and exit points. IBTimes reported that the photos can be kept for up to 75 years 5. The EU-US PNR agreement lets DHS keep PNR for up to five years in an active database and up to ten more in a dormant one 16.
How to ask for your data in the EU
The GDPR gives you a right of access. You can get a copy of your data, the purposes of processing, the recipients, the planned retention period, the source of the data and whether automated decisions are made about you 9. The controller must reply within one month. It can extend by two months for complex or numerous requests, but must tell you why within the first month 8. Access is free in most cases. A fee or refusal is possible only for requests that are manifestly unfounded or excessive 8.
Send separate requests to the airline, the airport and any border or police body. Each one decides its own answer. Look for the data protection officer in each privacy notice. If you get no reply, you can complain to a data protection authority 9.
Police and border data follow other rules. GDPR does not cover processing for criminal law enforcement, which falls under Directive (EU) 2016/680. National law can restrict access rights to protect public security or prevent crime 17. Requests about PNR or Entry/Exit records go to national authorities. They can be partly refused.
- Name the trip, dates, flight numbers and booking reference.
- Ask for API, PNR, boarding records and any face images or templates.
- Ask who received the data and how long it will be kept 9.
- Keep a record of when you sent the request.
Non-EU examples: the UK and the US
The UK keeps a GDPR-style right of access, called a subject access request. The Information Commissioner's Office (ICO) says organisations normally have one month to reply, with up to two more months for complex requests 11,12. They normally cannot charge. Intelligence services may charge £10 12. The extension does not apply to information held for law enforcement 12. Requests can go online, by email, by post, by phone or in person 11.
In the US, the main route is the Freedom of Information Act. CBP accepts requests through its FOIA SecureRelease portal or by post, and points users to the DHS portal 13. If you think a watch list or screening problem caused delays or denied boarding, the separate DHS Traveler Redress Inquiry Program (DHS TRIP) handles that 18.
Common questions
Does the airline keep a copy of my passport?
It keeps the passport data it collects. In the EU it must delete API 48 hours after the government router receives it, though it may keep data for business needs where other law allows 1.
Can I refuse a face scan at the airport?
In the US, citizens can decline CBP photos and ask for a manual check 4. For airline or airport face boarding in the EU, the EDPB says the system design must give passengers control 3.
How long does the US keep my photo?
CBP says US citizens' photos are kept for no more than 12 hours after verification 4. Photos of non-citizens can be kept for up to 75 years, according to reporting on the 2025 rule 5.
Who do I ask for my Entry/Exit System record?
The record is held by border authorities of Schengen states. National law governs access and can restrict it for security reasons 17. The system keeps most records for three years 7.
Is a subject access request free?
Usually yes, in the EU and UK. A fee is possible only for manifestly unfounded or excessive requests 8,12.
Related
Sources
- EUR-Lex: Regulation (EU) 2025/12 on the collection and transfer of advance passenger information (19 December 2024)
- IATA: Passenger data (accessed 19 October 2026)
- European Data Protection Board: Opinion 11/2024 on the use of facial recognition to streamline airport passengers' flow (23 May 2024)
- US Customs and Border Protection: Biometric privacy policy (accessed 19 October 2026)
- IBTimes: U.S. to photograph and track every non-citizen entering or leaving the country under new rule (27 October 2025)
- European Commission, Migration and Home Affairs: Entry/Exit System (accessed 19 October 2026)
- EUR-Lex: Regulation (EU) 2017/2226 establishing the Entry/Exit System, recitals on retention (2017)
- GDPR text: Article 12, transparent information and modalities (Regulation (EU) 2016/679)
- GDPR text: Article 15, right of access by the data subject
- GDPR text: Article 28, processor
- UK Information Commissioner's Office: Getting copies of your information (subject access request)
- UK Information Commissioner's Office: What to expect after making a subject access request
- US Customs and Border Protection: Freedom of Information Act (accessed 19 October 2026)
- EUR-Lex: Directive (EU) 2016/681 on the use of PNR data (27 April 2016)
- Court of Justice of the EU: Press release 105/22, Case C-817/19 Ligue des droits humains (21 June 2022), copy hosted by Statewatch
- EUR-Lex: Agreement between the US and the EU on the use and transfer of PNR to DHS (OJ 11 August 2012)
- EUR-Lex: Regulation (EU) 2016/679 (GDPR), recitals 19 and 73 (27 April 2016)
- US Department of Homeland Security: DHS Traveler Redress Inquiry Program (DHS TRIP) (last updated 28 June 2022)
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