Children's data at borders: API fields, biometrics and consent letters

Same document data as adults

Advance passenger information (API) is collected for every passenger on a manifest, whatever their age. The US vessel manifest rule, for example, requires full name, date of birth, gender, citizenship and travel document details for all passengers and crew ⁹.

Under the Schengen Borders Code, minors crossing an external border are subject to the same checks on entry and exit as adults. Border guards must pay particular attention to minors, whether travelling with an adult or alone ³.

Extra fields for unaccompanied minors

Airline booking data (PNR) can carry notes about children travelling alone. In the EU PNR Directive (EU) 2016/681 of 27 April 2016, item 12 of Annex I covers general remarks, including all available information on unaccompanied minors under 18 years ⁴.

The UK lists similar items in Schedule 2 to the Immigration and Police (Passenger, Crew and Service Information) Order 2008. Carriers supply these to the extent the information is known to them ⁵.

• The fact that the passenger is under 18 and unaccompanied (paragraph 1(pp)) ⁵
• Age, languages spoken and special instructions (paragraph 1(qq)) ⁵
• Departure, transit and arrival agents who receive care instructions (paragraph 1(qq)) ⁵
• Name, address, telephone number and relationship to the passenger of the guardian on departure and the guardian on arrival (paragraph 1(qq)(vii) and (viii)) ⁵

Biometric age limits

Age thresholds differ by system and by type of biometric. The table sets out what each rule states ^{1,2 6}.

Facial images of children

The European Commission says the EES records name, travel document data, fingerprints and captured facial images, plus dates and places of entry and exit ⁷. The under-12 exemption in Article 17(3) of the EES Regulation refers to fingerprints ¹.

In the United States, 8 CFR 235.1 lets DHS require an alien seeking admission to be photographed. The age exemption in paragraph (f)(1)(vi) applies to other biometrics under paragraph (f)(1)(iii), not to photographs ².

Proof of relationship and consent letters

Border officers may ask adults to show they have the right to travel with a child. Under the Schengen Borders Code, guards check that adults with a minor have parental care. Where there are serious grounds to suspect a child was unlawfully removed, they investigate further. Member States name national contact points for consultation on minors ³.

GOV.UK says travellers to the UK may be asked to prove their relationship to a child if they do not seem to be the parent. Accepted evidence includes a birth or adoption certificate, divorce or marriage certificates where surnames differ, and a letter from the child's parent giving permission and contact details ⁸.

Global Affairs Canada says a consent letter is not legally required in Canada, but border and airline staff may ask for one. It recommends one for any child under 19 travelling without both parents or decision-makers. The letter should be signed by each parent not travelling, and a notary public is strongly recommended as witness ¹⁰.