- Purpose
To ensure compliance with the Illinois Biometric Information Privacy Act (“BIPA”), Great Northern Instore (the “Company” or “GNI”) has adopted this Biometric Data Policy and Notice (this “Policy”) to govern the collection, capture, use, safeguarding, retention, and deletion of GNI’s hourly team members’ Biometric Data, as that term is specifically defined in this Policy. - Scope
This Policy applies to any GNI hourly team member who uses the time clock at GNI, as well as any GNI approved third-party service provider engaged by GNI, who under this Policy and on behalf of GNI, as applicable, captures, collects, uses, processes and/or retains GNI’s hourly team members’ Biometric Data, as that term is specifically defined in this Policy, for the purposes set forth in this Policy. - Definitions
“Biometric Data” means the specific Biometric Identifier and/or Biometric Information defined and set forth under this Policy.
“Biometric Identifier” means a unique biological characteristic used to identify a GNI hourly team member under this Policy, including but not limited to: Fingerprint
“Biometric Information” means information, regardless of how it is, captured, collected, processed, converted, stored, or shared, which is based on the Biometric Identifier set forth under this Policy. Biometric Data does not include information derived from items or procedures excluded under the definition of Biometric Identifiers under applicable law. - Retention Schedule
GNI, through its approved third-party service provider, may retain the team member’s Biometric Data until the earlier of (a) the team member’s employment with GNI being terminated for any reason, regardless of whether the termination is voluntary or involuntary; or (b) the team member notifying GNI that the team member is revoking the team member’s written consent to collect, use and retain the team member’s fingerprint data for the purposes set forth in this Policy. GNI, through its approved third-party service provider, will permanently delete the team member’s Biometric Data set forth under this Policy upon the earlier occurrence of (a) or (b) above of. - Biometric Data Collection
Biometric Date captured or collected and retained pursuant to this Policy is being used to verify all GNI’s hourly team members’ identity for time and attendance purposes, to ensure payroll is processed accurately and to prevent buddy punching. - Biometric Data Security
GNI, through its approved third-party service provider, shall use a reasonable standard of care to, as applicable, capture, collect, store, process, transmit and protect from disclosure any paper or electronic Biometric Data collected under this Policy. - Biometric Data Disclosures
Subject to each GNI hourly team member’s written consent, GNI may disclose that team member’s Biometric Data, as defined in this Policy, to its approved third-party service provider for the purposes set forth in this Policy.GNI prohibits any further disclosure or re-disclosure of team member Biometric Data under this Policy unless:
- The team member or the legally authorized representative of the team member consents to the disclosure;
- The disclosure is required by applicable law or regulation; or
- The disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.
GNI does not sell, lease, trade, or otherwise profit from team member Biometric Data.
