Privacy groups such as the Electronic Frontier Foundation (EFF) have warned that in addition to criminal mugshots, IPS will also have access to civilian photographs. Roughly 4.3 million of the database's 52 million photos will be civilian images by 2015, taken for non-criminal purposes like employment identification.

The FBI and Congress have thus far failed to enact meaningful restrictions on what types of data can be submitted to the system, who can access the data, and how the data can be used."