TreeRing Workforce Solutions Privacy Policy for the Processing of Biometric Data from U.S. Residents
TreeRing Workforce Solutions has instituted the following policy related to any U.S. resident biometric data that is collected, processed and/or stored by TreeRing Workforce Solutions and that is subject to the requirements of any law expressly governing the collection, storage, use and/or disclosure of biometric data.
Not all TreeRing Workforce Solutions products and services utilize biometric technologies, and not all of TreeRing Workforce Solutions’s biometric technology products and services involve TreeRing Workforce Solutions’s participation in the collection, storage or use of biometric data (for example, products sold by third-party partners). However, in some cases, TreeRing Workforce Solutions may provide hosting services for certain biometric data collected by Customer on such Customer’s behalf.
Biometric Information
The biometric data covered by this policy includes “Biometric Identifiers” as defined by BIPA (i.e., a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry) and “Biometric Information” as defined by BIPA (i.e., any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s Biometric Identifier used to identify an individual).
At the direction and on behalf of its Customers, TreeRing Workforce Solutions may collect, store and/or use biometric data. Customers may utilize TreeRing Workforce Solutions’s products and services to collect, store and/or use biometric data solely for employment-related purposes, including tracking of time and attendance, in accordance with this policy and applicable law.
Customer’s Responsibilities
It is the sole responsibility of the Customer that collects, captures, stores, or otherwise uses Biometric Data relating to an individual, to:
- Inform the individual from whom Biometric Data will be collected, in writing and prior to collecting the individual’s Biometric Data, that Biometric Data is being collected, stored, and/or used.
- Indicate, in writing, the specific purpose(s) and length of time for which Biometric Data is being collected, stored, and/or used.
- Receive a written release from the individual (or a legally authorized representative) authorizing the Customer and TreeRing Workforce Solutions to collect, store, and/or use the Biometric Data and authorizing the Customer to disclose such Biometric Data to TreeRing Workforce Solutions and any Customer third-party service providers.
- Develop, maintain, and to inform all individuals about any Customer policies for Biometric Data collection. Customer must maintain its own data collection, disclosure, retention, and storage policies in compliance with all applicable laws. Where required by law, Customer agrees to adopt a privacy policy in alignment all applicable laws governing the collection, use, transfer and retention of Personal Data.
- Ensure that TreeRing Workforce Solutions is immediately notified upon termination or other discontinuation of use of TreeRing Workforce Solutions’s biometric products or services with respect to an employee or other individual.
Disclosure and Sharing of Biometric Information
TreeRing Workforce Solutions will not sell, lease, trade or otherwise profit from any biometric data that it receives from Customer’s employees. Biometric data will not be used for any purpose other than as described herein.
TreeRing Workforce Solutions will not disclose, redisclose or otherwise disseminate any biometric data received from Customers to any person or entity other than TreeRing Workforce Solutions and TreeRing Workforce Solutions’s third party service providers except for if disclosure or redisclosure is required by state or federal law or municipal ordinance or disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.
Note Regarding Illinois Biometric Information Privacy Act
In accordance with the Illinois Biometric Information Privacy Act (740 Ill. Comp. Stat. Ann. 14/1 et seq.) (the “Illinois BIPA”), TreeRing Workforce Solutions maintains comprehensive policies and procedures to ensure the proper collection, use, safeguarding, storage, retention, and destruction of Biometric Data by TreeRing Workforce Solutions. As required by the Illinois BIPA, TreeRing Workforce Solutions makes available its Biometric Data Retention and Storage policies in the following sections. For purposes of clarity, these policies apply to all Customer Personal Data, not just Customer Personal Data collected in Illinois.
Retention of Biometric Information
TreeRing Workforce Solutions shall retain biometric data for up to ninety-seven (97) days after receiving notice from customers, or its employees notice that the employment with the customer has ended. TreeRing Workforce Solutions shall permanently destroy all copies of the employee’s Biometric Data in its possession after the time period is elapsed unless TreeRing Workforce Solutions is required to hold Customer Personal Data pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.
Storage of Biometric Information
TreeRing Workforce Solutions will use a reasonable standard of care, consistent with the industry in which TreeRing Workforce Solutions operates, to store, transmit and protect from disclosure all biometric data, and shall store, transmit, and protect from disclosure all biometric data in a manner that is the same as or more protective than the manner in which TreeRing Workforce Solutions stores, transmits, and protects other confidential or sensitive data that can be used to uniquely identify an individual or an individual’s account or property.
Contact Information
If you have any questions about the Service or this Agreement, you may call us at 1-855-861-4381, email us at support@TreeRingWS.com
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