04/30/2026
In a case of first impression, Vaziri Law LLC was recently successful in arguing before the Third District Appellate Court that the government contractor exemption in the Illinois Biometric Information Privacy Act does not cloak an entity’s entire operation simply because it possesses a government contract. The panel held, “Read completely, the exclusion exempts government contractors at the time they are serving a state agency or local government unit, the panel said. As such, they are exempt from BIPA's requirements when they are operating within the scope of their contractual relationship with the government, it held. And conversely, "a government contractor is not exempt when it violates the act while pursuing private undertakings outside of its government contractual responsibilities," the panel said. Link to full opinion:
