As explained in 12, some limited segments of American society have expressed religious objections to the use of biometrics. Although these religious-based concerns may not on the surface appear to implicate privacy issues, the constitutionally protected right to the free exercise of religion can be understood to vindicate privacy-related values. Some individuals oppose being compelled to participate in a government program that mandates the provision of a biometric identifier. These religious-based refusals raise a sensitive issue, in which the intrusion on the free exercise of religion must be carefully weighed. Some real-world cases provide guidance as to how the law reacts to such refusals. For example, the New York Department of Social Services and the Connecticut Department of Social Services (DSS) have encountered legal challenges based on religious concerns from entitlement program recipients who refused to provide a biometric
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