Wash. Rev. Code § 59.18 § 59.18.760
Smart access systems -- User data collection.
Operative Text
(1) A landlord of a smart access building or third party may collect only the minimum amount of authentication data and reference data necessary to enable the use of a smart access system for the purpose of granting a user access to a building, its elevators, its common areas, or to a user's dwelling. (2) A smart access system may only collect, generate, or utilize the following information: (a) A user's name; (b) The dwelling unit number and other doors or common areas to which the user has access using a smart access system in a building; (c) A user's preferred method of contact; (d) A user's biometric identifier information if a smart access system utilizes biometric identifier information; (e) The identification card number or any identifier associated with the physical hardware used to facilitate building entry, including radio frequency identification card, bluetooth, or other similar technical protocols; (f) Passwords, passcodes, user names, and contact information used singly or in conjunction with other reference data to grant a user entry to a smart access building, dwelling unit of a building, or common area of a building through the building's smart access system, or to access any online tools used to manage user accounts related to a building; (g) Lease information, including move-in and, if available, move-out dates; and (h) The time and method of access, solely for security and operational purposes.
Washington law under Wash. Rev. Code § 59.18.760 limits what data a landlord or third-party operator of a 'smart access building' may collect through an electronic entry system. Only the minimum authentication and reference data needed to grant building access is permitted, and the types of collectible data are specifically enumerated — including names, unit numbers, biometric identifiers (if used), access credentials, lease dates, and access logs for security purposes. No data beyond this defined list may be gathered through the smart access system.
Plain English — not legal advice.
Under Wash. Rev. Code § 59.18.760, operators of smart access buildings are generally expected to configure their systems — and any third-party vendors they engage — to collect only the data categories explicitly listed in the statute, such as user names, unit numbers, access credentials, and time-of-access logs used solely for security and operational purposes. Compliant operators typically audit their smart access vendors to confirm that data collection is limited to the minimum necessary and does not extend to categories outside the statutory list. Contracts with third-party system providers often reflect these data-minimization obligations to ensure downstream compliance with § 59.18.760.
General guidance for property managers — not legal advice for your specific situation. Consult an attorney for advice on your case.
Wash. Rev. Code § 59.18.760 gives tenants in smart access buildings a right to have their personal data — including any biometric identifier information — collected only to the minimum extent necessary and only within the categories the statute explicitly permits. If a tenant believes a landlord or third-party system is collecting data beyond what § 59.18.760 allows, general enforcement paths may include raising the issue with the landlord in writing, consulting a tenant-rights organization familiar with Washington housing law, or exploring whether a complaint to a relevant state agency is appropriate. Tenants may also wish to review any smart access system agreements they signed to understand what data practices were disclosed.
General guidance for tenants — not legal advice for your specific situation. Consult a tenant-rights organization or attorney for advice on your case.
Generated October 7, 2026 — auto-generated, not yet human-reviewed. See /transparency for methodology.
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