「Lawyer Interpretation」

The implementation of the "Measures for the Safety Management of Face Recognition Technology Application" has set a legal boundary for facial recognition applications in marathon events. The events organizers must follow "non-unique principle" and shall not force facial recognition as the only verification method. They must open such ID card verification as substitute channels simultaneously. At the same time, the "separate consent" requirement must be implemented: the use of facial information(only for events verification), storage period(recommended to be deleted 30 days after events) and responsibility for breach of contract(if the usage exceeds the range, a compensation of three times the registration fee will be required), also the bundled authorization trap shall be eliminated.

For the use of portraits, the unauthorized salesperson's portrait violates Article 1019* of the Civil Code and Article 4 of the Measures "Purpose Limitation Principle". Compliance solutions require dual-track parallelism: commercial image sales must obtain secondary authorization from the competitors; Technical distinguishes data strictly: local encrypted storage of objected information, track photos are desensitized and then uploaded to the cloud.

The essence of compliance lies in the balance of rights: technical efficiency must not override personal dignity. The events organizers should take the independent authorization letter as contract commencement point and use technical isolation as the shield to implement the "face autonomy" truly of tens of thousands of runners: this is the core essence of the Measures to promote the "goodness" of technology.

*Article 1019 of the Civil Code: No organizations or individuals may infringe on the portrait rights of others by vilifying, staining, or using information technology to forge them. No portraits may be made, used or disclosed without the consent of the portrait right holder, unless otherwise provided by law.

Shaanxi Hongye Law Firm

Meng Fanzhen

In March 2025, the State Internet Information Office and the Ministry of Public Security announced the "Measures for the Safety Management of Face Recognition Technology Application" jointly(hereinafter referred as "Measures"), and it will be implemented officially on June 1, 2025. The core goal of this new regulation points to the current rampant "face scanning" phenomenon: standardizing the application of facial recognition technology and protecting personal information rights.

In the field of marathon events, facial recognition technology has been popularized quietly. From the first "People Certificate Verification" of the Shenzhen "Baibin 100" cross-country race in 2017 to the full application of the face recognition system in 2023 Guangzhou Marathon, this technology has become the standard equipment for the events rapidly.

「Optimization of Operational Efficiency」

Face recognition technology has achieved remarkable results in improving the level of events management.

Taking the process of receiving items as an example, the traditional manual identity verification method is time-consuming and labor-intensive, and it is easy to form a peak in events held, resulting in players waiting for a long time. This situation has been improved greatly after importing facial recognition technology.

In 2024, a certain event adopted AI face recognition technology, and the time for players to receive number bibs shortened to 20 seconds. It realized "real-time information binding+face-level verification", changing the traditional manual search mode completely.

Figure 1.  "Real-time information binding+face second-level verification" application report

In 2023, a certain event realized "unauthorized pass" during the entry of events. In the same time, temperature measurement and identity verification were completed simultaneously, and the passage efficiency was improved by 300%.

According to relevant statistics, the events which using facial recognition systems, the average efficiency of receiving items has increased by 30% to 50%. In the past, most players completed the process need take several hours, but now, they can complete in half hour.

「Breakthrough in Anti-Cheating Performance」

In the event registration processes, facial recognition technology also plays an important role.

In 2018, a certain event imported a dual anti-cheating mechanism of "face recognition+event bracelets", claiming to intercept more than 100 impostors in a single game. In 2019, a certain event launched a facial recognition system testing for the first time. When 100 mixed inspection personnel passed the security inspection channel, the system locked 6 unregistered people instantly, which shocked the industry, and the technology has been popularized rapidly since then. In 2023, a certain event eliminated the phenomenon of substitute running through the facial recognition system, and reported cases of lifelong bans after the event to  maintain the fairness effectively.

Figure 2.  Report on the application of facial recognition system to eliminate running cheating

In the past, relying on manual verification of players identity information was not only inefficient, but also difficult to identify violations accurately such as instead of running and free for running. Now, through the facial recognition system, it can verify identity quickly and accurately, effectively ensuring the fairness and justice of the competition.

Before the "Measures" introduced, due to the lack of clear norms and standards, facial recognition technology was used in marathon events in different ways, which also led to some situations that damage athletes' privacy right and right to know. There are blind spots in the application of technology, which mainly exposes three typical problems.

「The Uniqueness of Choice Under the Rigid Requirements of Collection Process」

Some events use facial recognition as the only way to verify identity. According to incomplete statistics, about 20%-30% of the events did not provide other processes of verifying items, which made athletes have to accept facial recognition, otherwise they would not be able to receive items. This to a certain extent limits the athletes' right to choose.

「Blurry Reminder of Informed Consent Mechanism」

In partial registration pages, the settings of relevant terms for facial information processing are hidden relatively. Athletes need to click and pull down pages repeatedly to find relevant instructions. These instructions are often accompanied by complex and obscure professional terms, which ordinary athletes find it difficult to understand.

Some events tie face information collection authorization with many other terms, and do not give athletes the opportunity to choose whether to authorize it alone. There are also cases that some events have vague promises to "delete after the game" and have not clarified the storage period of facial information.

「Privacy Confidentiality of Track Shooting」

Some event photo platforms set up cumbersome face verification processes when athletes obtain photos, and during the verification process, pages that pay to purchase high-definition photos or photo packages frequently pop up, interfering athletes' normal operations. Some platforms use the photos to make profits or use them for commercial purposes without obtaining the athletes' clear authorization, such as advertising promotion, products promotion, etc.. These infringe athletes' portrait rights seriously.

A typical case was 2025 a certain event, the "Aiyundong" platform uploaded 550,000 high-definition photos of athletes without authorization. Users could only pay 20 RMB to download other people's photos, even sold video packages to make profits. Previously, several events organizing committees issued public letters to ask Aiyundong to stop infringement of filming.

Figure 3.  The organizing committee of relevant events issued a lawyer's letter announcement

In addition, some events have unreasonable aspects in terms of photos copyright ownership. The copyright of the photos that should belonged to the athletes eventually all went to the organizing committees. If the athletes want to download and use their own photos, they have to pay an additional fee. In 2023, the AI system a certain event used Ai system automatically generating videos of athletes, but the users agreement stated "the image copyright belongs to the organizing committee", and one's own face has become a resource for others to make profits.

Figure 4.  "Image Copyright belongs to the Organizing Committee" Event Statement

In response to the above phenomenons, Article 5 of the Measures:"Before using facial recognition technology to process facial information, personal information processors should inform individuals of relevant matters in a prominent manner, clear and easy-to-understand language"; Article 6:"If a personal consent is used to process facial information, it should obtain individual voluntary and explicitly agreed upon by the individual under the premise of full knowledge"; Article 8:"The retention period shall not exceed the shortest time to achieve the purpose" and other regulations have put forward rational provisions for them, and also provide a clear basis for the subsequent application of competition technology.

The issuance of the Measures has established a clear technical security boundary for the industry. It achieves standardized governance through four major mechanisms.

First, establishing the principle of "non-uniqueness" and requiring the events organizers to provide alternative verification channels, such as a certain event opens manual verification for religious taboos and allows plastic surgery athletes to pass chip verification.

Second, enhancing the transparency of information, and stipulating that the storage period should be notified in prominent ways such as pop-up windows(such as 30 days after the event will be deleted). Shanghai Special Governance also requires the setting of a separate "face authorization" option.

Third, establishing a data security isolation mechanism, stipulating that facial information must not be transmitted over the Internet. The receiving items system must use a localized storage terminal, and track photos can only be used for cloud access after desensitization.

Fourth, implementing hierarchical supervision and establishing a provincial filing system for events that handle more than 100,000 facial information. Chongqing has included this field in "Special Governance of Biometrics" and issued the first violation ticket.

The implementation of the new regulations promotes the transformation of facial recognition technology from an "efficiency tool" to a "compliance assistant", which is essentially an institutionalized return to scientific and technological ethics. When Chongqing Marathon set up a "tiring channel" at the end point, and when the Berlin Marathon system realized photos cloud desensitization, the boundaries of technical applications gradually become clear.

True respect is not just a slogan, but a practical action to abandon the trap of clauses and misleading operations. The core of the events development is transforming respect into clear options: the registration pages states clearly that "face recognition is not mandatory", and the authorization letter states the countdown to data deletion, so that every face has the right to refuse. Only when the organizers are willing to exchange half efficiency for a guarantee of rights, the athletes are not only touching the medals but also the privacy and dignity protected, marathon can break through the shackles of commerce and reach the core of sportsmanship.

The destination of technical services should be the starting point of restoration of rights. A more comprehensive era of digital human rights protection is accelerating inside and outside the track. The implementation of the Measures not only sets an operational red line for the event organizers, but also promotes the formation of new consensus in industry:

A true wisdom marathon never erects a technical fence in front of the camera, but allows every face to enjoy the convenience of technology and the right to say no.