[sebmellen]

Not only is it PII, it is also a biometric identifier under BIPA [0]. Perhaps moreso than a facial image alone (depending upon your interpretation of the law).

[0]: https://www.ilga.gov/Legislation/publicacts/view/095-0994

> "Biometric identifier" means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. Biometric identifiers do not include writing samples, written signatures, photographs, human biological samples used for valid scientific testing or screening, demographic data, tattoo descriptions, or physical descriptions such as height, weight, hair color, or eye color.