Biometric Information Gathering and Retention Policy and Consent

Crawford Steel uses a Paychex biometric clock for the purpose of documenting employees’ attendance. 

Under Illinois law, your fingerprints are considered a “biometric identifier” and their use is regulated by the Biometric Information Privacy Act (the “Act”), located at 740 ILCS 14/1, et seq.  Under the Act, you are entitled to the following disclosures regarding the use of your biometric identifiers:

• Crawford Steel uses a fingerprint scanner in the Paychex time clock to create a digital image of the employee’s fingerprint in the form of a template. The template is a representation or algorithm, or code, using numbers or letters, of the fingerprint and the template/algorithm/code is created for just the employee in an encrypted format. The fingerprint is not stored in the Paychex time clock and cannot be replicated to re-create the original images of your finger;
• The Paychex time clock uses employees’ ID number and fingerprint template/algorithm/code (not the actual fingerprint) to enable employees to clock-in and clock-out in a quick and accurate manner for payroll purposes;
• Crawford Steel will store your template/algorithm/code in the Paychex timeclock only for the duration of your employment in accordance with Crawford Steel’s retention policy for biometric information.

The Act defines “biometric identifiers” as including fingerprints. The Act further defines “biometric information” as any information based on an individual’s biometric identifier used to identify an individual, such as a template or a code. Under the Act, Crawford Steel is required to make available to the public a written policy establishing a retention schedule and guidelines for permanently destroying biometric information, such as fingerprint templates/algorithms/codes. This document contains our policy and retention schedule and guidelines. Our biometric policy and retention schedule and guidelines are also available on our website at www.crawfordsteel.net/biometics.

Furthermore, 

• Reports that list or view some or all of the biometric templates/algorithms/codes stored in the biometric clock may be run. These reports do not contain information about the employee’s fingerprint, but the template that the clock created. The reports also contain statistics about the biometrics, such as the time of punch in and out and the number of times that the device could not associate a template/algorithm/code with the ID number entered by an employee.
• The information will only be collected and stored by the Paychex time clock for purposes relating to Crawford Steel’s monitoring of its employees’ attendance. The clock can create a report of each employee’s time in and out that Crawford Steel and Paychex can review to document and calculate payroll.
• Any biometric information will only be collected, stored and used as long as the employee is employed by Crawford Steel. Crawford Steel will inform Paychex when an employee’s employment has concluded or within 3 years of the individual’s last interaction with Crawford Steel, whichever occurs first, unless otherwise required by law, and the biometric information, meaning the template/algorithm/code assigned by the software to the employee, will be deleted from the biometric clock. The employee ID number and the dates and times the employee punched in and out will still be maintained.
• Absent receipt of a valid warrant or subpoena seeking the information, the employee’s biometric information will be destroyed by deleting the employee’s information from the clock.

Crawford Steel will only use your biometric identifiers and biometric information for the purposes described above, and only in a manner that is consistent with the Act. Under the Act, neither Crawford Steel nor Paychex may sell, lease, trade, or otherwise profit from your biometric identifiers or biometric information. Under the Act, neither Crawford Steel nor Paychex may disclose your biometric identifiers or biometric information unless: (1) you or your legally authorized representative consents to the disclosure; (2) the disclosure completes a financial transaction initiated or requested by you or your legally authorized representative; (3) the disclosure is required by local, state or federal law; or (4) the disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.

Unless an employee decides to opt out and use a phone app, or a different, approved, process for time keeping, all existing and future employees using the biometric time clock are required to sign, as a condition of employment, an acknowledgement of this policy that consents to Crawford Steel’s and its payroll vendor’s, Paychex’s, obtaining, storing, and utilizing the employee’s biometric data and corresponding information.  Please see Human Resources if you are interested in using a phone app or different time keeping process.

I, _________________________________, have reviewed and received Crawford Steel’s Biometric Information and Gathering and Retention Policy and hereby release, consent and authorize Crawford Steel’s obtaining, storing and utilization of my finger and biometric information pursuant to that policy. I understand that I can opt out of using the biometric clock by using a phone app, or a different, approved, process for time keeping and will see Human Resources if I am interested in using a phone app or different time keeping process.

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Employee Signature            

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Date