Introduction
This Biometric Information Policy (this “Policy”) is integral to the use of Inn-Flow’s Labor Management Timeclock app, which employs facial recognition technology for clocking individual employees, contractors or other workers (referred to in this Policy as “users”) in and out. This Policy outlines the practices related to the collection, use, disclosure, retention and storage of individual users’ facial recognition data to ensure transparency and obtain users’ informed consent.
Consent and Acknowledgment
When a user first attempts to use the facial recognition feature of our Timeclock app, the user will be provided with a copy of this Policy and asked to register the user’s consent. By clicking “I Agree” or selecting a similar option when presented, the user acknowledges that the user has read, understood, and agreed to this Policy. Consent is obtained explicitly before a user’s first facial scan.
What Data Is Collected?
Following the user’s consent, at the time a user clocks in and clocks out using the Labor Management Timeclock app, the app captures photographic images of the user’s face, to be processed and used by the Timeclock app for recognition and verification of each individual. No other biometric data (e.g., scans of facial geometry, retina or iris scans, hand or fingerprint scans, voiceprints, etc.) of users is collected.
Purpose of Collection
The facial recognition technology is employed to accurately record time entries, enhancing the efficiency of time tracking and ensuring the integrity of labor management within Inn-Flow’s system. This technology serves to prevent fraudulent time logging and to facilitate a seamless and secure method of authentication for employees.
Data Collection Process
Before the initiation of the facial recognition process, employees will be informed of this Policy and the specifics of data collection. Consent will be explicitly obtained prior to the first facial scan. Only facial recognition data necessary for the purpose of authenticating and recording time entries will be collected.
Storage and Security
Facial recognition data collected through the Timeclock app is stored within Inn-Flow’s third party hosted/cloud services provider, Microsoft Azure. We and the hosted/cloud services provider each have implemented certain security measures designed to protect against unauthorized access, disclosure, alteration, or destruction of this facial recognition data.
Use and Disclosure of Facial Recognition Data
The collected facial recognition data is used exclusively for the purposes of authenticating the identity of users and recording their time entries. The facial recognition data will be shared with our third party hosted/cloud services provider that we use to support the provision and operation of this service, Microsoft Azure as noted above, solely to enable this services provider to process this data on our behalf as necessary to provide and operate this service (and for no other purpose). Additionally, upon an employer’s request the user’s facial recognition data may also be shared with the user’s employer for their use in connection with their employment or other contractual relationship with the user. Otherwise, the data is not shared with third parties nor used for any purpose other than those explicitly stated in this Policy.
Retention Period
Facial recognition data is retained only for as long as necessary to serve its purpose in labor management and compliance with our record-keeping policies. The retention period for biometric data is 6 months per the most recent scan, after which the data and images are permanently deleted or destroyed.
Changes to Policy
We reserve the right to modify this Policy at any time. Any changes will be communicated through the Timeclock app or via company communication channels. If we make material changes to our policies for the collection, use, disclosure, retention and/or storage of facial recognition data, we will collect the applicable user’s consent to the changed policies before applying or implementing them as to the applicable user.
Contact Information
For questions or concerns regarding this Policy or the handling of facial recognition data, please contact support@inn-flow.com.