HB 4514 authorizes the Texas Department of Public Safety (DPS) to use its facial recognition-based image verification system to confirm an individual’s identity, contingent upon the individual’s consent and the submission of a facial image and required information. The system—originally created for law enforcement—would now be available for broader identity verification purposes under controlled conditions, as long as a memorandum of understanding is signed between DPS and the requesting entity.
The bill allows DPS to charge a fee for each verification request, with the amount determined by rule to fully cover the costs of system operation. The collected fees will be deposited into a special account within the General Revenue Fund and used exclusively for administering the verification program. Importantly, all submitted images and identifying information are deemed confidential and are exempt from public disclosure under the Public Information Act (Chapter 552, Government Code). DPS is required to destroy all submitted information after fulfilling or rejecting the request.
Furthermore, the bill authorizes DPS to contract with private vendors to process verification requests and mandates rulemaking by December 1, 2025, for full implementation. The bill takes effect September 1, 2025.
The original and substitute versions of HB 4514 both aim to authorize the Texas Department of Public Safety (DPS) to use its image verification system—specifically facial recognition technology—for identity verification purposes beyond traditional law enforcement use. However, there are several important distinctions between the original and Committee Substitute, particularly in terms of access controls, procedural structure, and funding mechanics.
In the original version, any person could request an identity verification from DPS, provided they submit a facial image and the subject’s name along with that individual's written consent and a fee. This version broadly enables access to the DPS facial recognition database with few upfront procedural requirements, raising questions about operational control and privacy enforcement. Conversely, the Committee Substitute restricts access by requiring a formal memorandum of understanding (MOU) between DPS and the requesting party, signaling a more controlled and accountable framework for third-party access.
Both versions include provisions requiring consent, confidentiality of submitted information, and destruction of data after a verification is completed or denied. However, the substitute bill goes further by mandating that rules be adopted to implement the data destruction requirement, providing clearer regulatory oversight. Additionally, while the original bill clarifies that it does not authorize disclosure of existing facial images from the DPS system, the substitute allows contracting with private vendors to process verification requests, introducing an external actor into the system.
A key fiscal difference lies in the funding mechanism. The original bill includes a provision that DPS must establish a fee to cover costs but does not specify where those funds go. The substitute bill, however, amends Section 521.058 to create a special account in the general revenue fund earmarked for DPS’s administration of the identity verification process. This change not only clarifies the fiscal pathway but also ensures that the revenue is ring-fenced for relevant program operations.
Overall, the Committee Substitute version of HB 4514 provides stronger safeguards, more structured oversight, and tighter procedural controls than the original. While both versions enable facial recognition for identity verification, the substitute narrows access, ensures more transparency around implementation, and integrates clearer financial and privacy guardrails. These changes likely reflect stakeholder concerns about privacy, data use, and the operational integrity of DPS's facial recognition infrastructure.