HPI TIMEKEEPING BIOMETRIC DATA POLICY
Home Products International-North America, Inc. (“HPI” or the “Company”) is committed to paying employees accurately and on-time.
Biometric Time Keeping System
To efficiently and accurately collect and store the hours worked by employees for payroll purposes, the Company has partnered with leading third-party vendors to implement a state of the art biometric timekeeping system. When clocking in for work or clocking out, instead of punching a timecard, entering an employee ID number or scanning an employee ID badge, the employees complete a two-step process. Employees first enter their employee ID number into the time clock and then scan their fingertip or hand to complete the process.
HPI’s timekeeping system does not actually collect or store fingerprints, palm prints, handprints, or images of the finger or hand scan. Instead, the timekeeping system measures certain aspects of an employee’s fingertip or hand. These measurements, which are the fingertip or hand biometric data points, are immediately converted into a unique mathematical representation of that data through the vendor’s proprietary software program. This data is then encrypted, linked to the employee’s employee ID number and saved in a “template”. Each time an employee clocks in for work or clocks out, a new scan of the employee’s fingertip or hand is taken. This new scan is compared to the “template” assigned to the employee’s personalized ID number to verify the identity of the employee.
Employee Consent to Collect of Biometric Data
As a condition of employment, employees of the Company will be required to give written consent allowing the Company to capture, collect and store biometric data from the finger or hand scan technology used for timekeeping purposes. However, the Company will consider requests by employees for accommodation or exemption in whole or in part from the use by the Company of finger or hand scan technology and biometric data for verification of employees’ identities and/or the procedures set forth in this HPI Timekeeping Biometric Data Policy.
Prior to giving consent, employees should read this HPI Timekeeping Biometric Data Policy, which is also available at any time through the Human Resources Department.
Confidentiality and Protection of Employee Biometric Data
The Company understands that in today’s world, employees may be concerned about the security of their personal information. With this in mind, the Company has carefully selected leading payroll system vendors that share the Company’s commitment to protecting confidential and sensitive information. The Company, and its vendors, will protect from disclosure all biometric data obtained through the finger or hand scan technology used by the Company’s timekeeping system using the reasonable standard of care within the industry. The Company’s commitment to employees is that this data will be protected to the same level as any other confidential and sensitive information.
During an employee’s employment and the biometric data retention periods outlined in this policy, the biometric data from the timekeeping system, which is stored by the Company’s vendors, is accessible only by Company representatives whose job duties require such access, or in limited and temporary circumstances by the vendors if database or system service is required.
The Company and its vendors will not sell, lease, trade, or otherwise profit from an employee’s biometric data. The Company will not, and the Company’s vendors will not, disclose or otherwise disseminate an employee’s biometric data without an employee’s consent unless required by any state or federal law, municipal ordinance, valid warrant, or valid subpoena.
Retention of Employee Biometric Data
Any employee biometric data collected will be retained by the Company for not longer than 1 year after the employee’s last use of the system or 1 year after termination of employment, whichever is sooner or for a different time period if required by law. The Company will permanently destroy an employee’s biometric data upon expiration of the aforesaid time periods.
Compliance with Federal, State and Local Law
This policy is intended to comply with all federal, state, and local laws, and will be interpreted and applied in order to comply with all applicable laws, including but not limited to, the Illinois Biometric Information Privacy Act.
Access to the Policy
If you have any questions about this policy, including how the finger or hand scan technology works, how the technology is used, or how the timekeeping system provides time records for the payroll process, or if you would like an additional copy of the policy, please contact HPI Human Resources Department.
The Company will also make a copy of this policy available to the public through the Company’s website.