Well done Alipay! Privacy concerns with facial recognition payment function

The 21st century is undoubtedly the beginning of the information age. Being a member of this period requires that you have a profound comprehension of this topic. Thanks to developments in fields such as artificial intelligence and the Internet of Things, facial recognition is becoming increasingly common in a variety of businesses, including the insurance industry, the financial sector, the security sector, education, and the entertainment industry. However, the digital privacy issues and other problems brought about by the broad application of facial recognition technology are gradually becoming more obvious at the same time.

What is facial recognition technology and its applications

The question is, how does facial recognition work in practise? What specific ways does it have the potential to simplify our lives? In detailed, the term “facial recognition” refers to the process of identifying individuals based on their facial appearance through the use of an algorithm. Then why is it beneficial to use face recognition technology? The following is a list of the inferences that I have made based on my own experiences as well as the findings of (McClellan, 2019)’s research:

  • Improving security: Facial recognition technology can be used to identify individuals who may pose a threat to public safety, such as criminals or terrorists. In addition, facial recognition is a non-Contact method. Unlike fingerprint recognition, which requires direct touch with the device, facial recognition may occur remotely. The device can get an accurate read on a person’s face from far away since it is an exposed biometric feature.
  • Recognition efficiency: When compared to more conventional techniques of identification, facial recognition is both faster and more accurate. You may have experienced that some traditional methods of identity recognition often make mistakes. My fingerprint often fails to open my own home’s password-protected lock. In addition, large-scale item detection may be performed automatically using facial recognition systems.
  • Convenience: Facial recognition technology can be used to quickly and easily verify a person’s identity, which may be useful in situations such as airport security checks or entering secure buildings. Facial recognition after partial occlusion, such as while wearing glasses or a mask, is supported by several systems; this could be a very useful feature during COVID-19.
  • Personalization: Facial recognition technology may be used to provide customized services such as targeted advertising or personalised suggestions.

To this day, it has maintained a level of maturity that is considered to be relatively high. In recent years, facial recognition technology has become increasingly popular, as you are probably already aware. In China, for example, train stations may now validate tickets using facial recognition rather than ID cards. The same goes for entry to schools and banks. The most commonly used application in daily life (at least for me) is facial recognition, which serves as a transaction password for various shopping platforms, including online shopping and even beverage vending machines in apartments.

Image Credit: A visitor tries facial recognition payment in a smart store in Wuzhen Town of Tongxiang, east China’s Zhejiang Province, Nov. 6, 2018: Huang Zongzhi

The controversial issues of facial recognition technology

Undoubtedly, facial recognition technology requires necessary hardware support to function properly, namely the camera. Cameras are usually associated with terms such as privacy, security, and surveillance in people’s minds. Please imagine a camera, whether it’s on your phone, computer, or surveillance. Next, imagine someone observing your life behind these cameras, knowing your name, appearance, and all your basic information. Do you feel a bit creepy and naturally imagine the camera as a voyeur although it is just a machine without intelligence?

Cameras are generally associated with terms such as privacy, security, and surveillance in people’s minds. It has been demonstrated that numerous different nations each have their own policies governing the utilisation of cameras. As far as I know, Japan and South Korea stipulate that mobile phones must have a shutter sound of no less than a certain decibel when taking photos. Consequently, when face recognition technology has advanced to such an advanced level, although individuals love the convenience brought about by facial recognition technology, it has also created worries among certain people over personal privacy, security, and accuracy. (Chan, 2022) stated that facial recognition is rapidly accepted and adopted around the world without effective supervision, which poses a moral and ethical challenge to people. In fact, history does not lack such precedents. For example, the rise of 4G technology has led to the rise of the live streaming industry, resulting in the birth of many live streaming platforms. At that time, the platform or government did not have effective measures to regulate live streaming content, which led to mixed content on live streaming platforms and even uncontrollable dissemination of pornography, fraudulent information, and so on. Today’s facial recognition technology also faces the same problem, as the degree of regulation seems to be inconsistent with the scope of application. The first and foremost issues are personal privacy and data protection.

Law and morality of Alipay facial recognition payment function

Even our techniques of making purchases have been revolutionised by the development of facial recognition technology. By 2025, the worldwide facial recognition industry is projected to be worth $10.9 billion, up from 2019’s $4.4 billion (Morder Intelligence, 2020). By 2023, (Goode Intelligence, 2018) predicted that 2.6 billion individuals will have made purchases using a mobile device. Adjustments must be made to adapt to changes in people’s payment ways in the face of such a massive volume, whether it be personal awareness, moral standards, or the development of legislative rules(Chan, 2022)

It has been proven that there are some regions in the world that have not fully opened up payment channels for facial recognition, not because of technical issues, but because of regulatory issues. For example, in the United States, there is still no unified law to regulate facial recognition technology (Liu et al., 2021)

However, this technology is already widely used in China. According to data, Alipay has become the world’s largest mobile payment system, and together with WeChat, it plays a leading role in China’s $5.7 trillion mobile payment field(Lu, 2018)So, as a leading country in the field of facial recognition payment, how does China handle legal issues related to facial recognition? Chinese state-owned enterprise UnionPay launched facial recognition payment function in October 2019, which means that this technology has gradually been accepted at the national level(Jao, 2019). At the legal level, in May 2020, the (Chinese Civil Code Law, n.d.)included biometric information in the category of personal information, stating that biometric information is protected by law, and in Article 1038, it is explicitly stated that network operators and information processors need to take necessary measures to ensure the security of personal information. At the corporate level, Alipay, as the world’s largest mobile payment system, launched its first “biometric user privacy and information security protection initiative” in early 2019. The initiative proposes that in order to prevent the misuse of customer biometric information, biometric data should be limited to the lowest possible level (Cortese, 2019). Although the management of biometric collection and application in China still needs improvement, it can be seen that from the national level to the private enterprise level, it is developing in a positive direction.

In addition to the legal aspect, it also requires support from network operators and information collectors at the moral level. Chan (2022) proposed an ethical code for facial recognition technology. This code emphasizes the importance of data privacy, security controls, and accuracy. The general content is:

  • When it comes to obtaining customer data privacy, it is necessary to obtain informed consent, clarify the content and scope of data collection, and ensure that data privacy is securely stored and disposed of.
  • Install security safeguards so that data cannot be accessed, used, or disclosed by unauthorised parties.
  • To ensure the accuracy of the facial recognition system, it is necessary to conduct regular testing and auditing of the system.
  • To avoid discrimination and bias, it is necessary to ensure the accuracy of interview recognition for different populations, and regular testing of facial recognition systems based on biometric data from different populations is necessary.
  • Provide clear information on the use of facial recognition technology and establish feedback mechanisms to promote transparency.

For the code of ethics, similar terms are found in Alipay Wallet Privacy Notice and General Rule for Biometric Recognition issued by Alipay. According to 1.4 and 1.5 of(General Rule for Biometric Recognition, 2022) and Part III, When Alipay employs a technology that uses facial recognition to acquire personal information from its users, it is vital to guarantee that users have been authenticated by their genuine names and that the company has obtained their consent. During the process of gathering, there will be precautions made to preserve the users’ personal privacy and guarantee the safety of their private information. After collecting information from users, Alipay made a commitment to secure the users’ personal information and identity data to the fullest extent possible, as well as their facial features, in accordance with applicable laws. These policies and commitments comply with the requirements of the first content of the Code of Ethics mentioned earlier. Meanwhile, in Article 1.8, it is pointed out that if the system believes that there is a risk when users use facial recognition functions, it will suspend the provision of facial recognition services to users, which is consistent with the requirements of Article 2 of the Code of Ethics. In the fourth part of the policy, Alipay promises to continuously update its services and provide users with services such as function update and internal use update. Although there is a correlation with 3 and 4 of the Code of Ethics, it does not explicitly mention the frequency and content of testing, as well as the treatment methods for different populations. Finally, Article 12 of the(Alipay Wallet Privacy Notice, 2020) elaborates on the user’s feedback mechanism, specifies the user’s rights, and how to use these rights, which is in accordance with the No.5 content of the Code of Ethics.

Image Credit: Process of Facial Payment Recognition: Leeloo Tang

It can be seen that Alipay, as the largest mobile payment platform in the world, abides by the code of ethics and respects the privacy of users when collecting users’ bio information technology. It provides a successful case for other enterprises to use biometric recognition technology in the future.

How to reduce privacy risks brought by facial recognition technology?

In today’s highly developed technology, people are enjoying the convenience brought by technology while being stripped of layers of clothing and swimming naked in the ocean of information. While it is unquestionable that technologies like facial recognition played a significant part in the past pandemic era, it is also essential to keep in mind that individuals have a right to personal privacy that cannot be violated. In order to correctly utilise facial recognition technology and stay clear of any potential dangers, the use of facial recognition technology by network operators and processors has to be regulated on a national level through the formulation of more extensive legislation and policies. At the corporate level, the firm needs to strengthen its self-discipline, ethical standards, and compliance with laws and regulations in order to be successful. When it comes to the users, it is vital to increase their understanding of the need to protect their personal information. It is imperative that all of us should maintain vigilance in order to prevent the disclosure of sensitive personal biological information in this day and age, when laws and regulations governing facial recognition have not yet been finalized.


Alipay Wallet Privacy Notice. (2020, February). https://render.alipay.com/p/f/agreementpages/alipaywalletprivacypolicy_en.html

Chan, J. (2022). Facial Recognition Technology and Ethical Issues. Proceedings of the Wellington Faculty of Engineering Ethics and Sustainability Symposium. https://doi.org/10.26686/wfeess.vi.7647

Chinese Civil Code Law. (n.d.). Retrieved April 9, 2023, from https://gkml.samr.gov.cn/nsjg/bgt/202106/t20210609_330453.html

Cortese A. J. (2019, December 21). Convenience or Concern? China’s Rampant Biometric Data Collection. Pandaily. https://pandaily.com/convenience-or-concern-chinas-rampant-biometric-data-collection/

General Rule for Biometric Recognition. (2022, October 8). https://render.alipay.com/p/yuyan/180020010001196791/preview.html?agreementId=AG00000013

Goode Intelligence. (2018). Biometrics for Payments – Market & Technology Analysis, Adoption Strategies and Forecasts 2018-2023. Goode Intelligence. https://www.goodeintelligence.com/report/biometrics-for-payments-market-technology-analysis-adoption-strategies-and-forecasts-2018-2023/

Jao N. (2019, October 21). State-backed UnionPay announces new facial recognition payment feature · TechNode. TechNode. http://technode.com/2019/10/21/state-backed-unionpay-announces-new-facial-recognition-payment-feature/

Liu, Y., Yan, W., & Hu, B. (2021). Resistance to facial recognition payment in China: The influence of privacy-related factors. Telecommunications Policy, 45(5), 102155. https://doi.org/10.1016/j.telpol.2021.102155

Lu L. (2018). Decoding Alipay: Mobile Payments, a Cashless Society and Regulatory Challenges (SSRN Scholarly Paper No. 3103751). https://papers.ssrn.com/abstract=3103751

McClellan, E. (2019). Facial Recognition Technology: Balancing the Benefits and Concerns. Journal of Business and Technology Law, 15, 363.

Morder Intelligence. (2020). Facial Recognition Market Size & Share Analysis—Industry Research Report—Growth Trends. https://www.mordorintelligence.com/industry-reports/facial-recognition-market

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