Purpose 

This document defines Prime Flight’s policy and procedures for the collection, use, safeguarding, storage, retention, and destruction of finger scan data by Prime Flight. 

Prime Flight uses employee finger scan data for employee timekeeping with regard to payroll.  Prime Flight and/or its vendor(s) collects, stores, and uses employee finger scan data for the purpose of identifying employees and recording time entries when utilizing Prime Flight’s timeclocks. Prime Flight has partnered with a leading third-party vendor to provide technology to efficiently and easily collect and/or store data for this purpose. 

Policy and Definitions 

Prime Flight’s policy is to collect, store and use biometric data in accordance with applicable standards and laws, including, but not limited to, the Illinois Biometric Information Privacy Act, 740 ILCS § 14/1, et seq.   

Procedure 

Collection of Finger Scan Data 

Prime Flight and/or its vendor(s) collects, stores, and uses finger scan data for the purposes of giving employees access to Prime Flight’s timekeeping systems and for maintaining accurate records of employee time.  When using our vendor’s timeclock system, finger scan data is generated that is immediately converted into a numerical template that is encrypted to protect against unauthorized access.  No fingerprint is ever taken or stored, and no image of the finger, or image of any kind, is stored as part of the enrollment or verification process.  The finger scan template generated by our vendor’s timeclock system consists solely of numerical data based on proprietary algorithms.  

In the event Prime Flight begins collecting data related to biometrics for any additional purpose, Prime Flight will update this document. 

Disclosure 

Prime Flight will not sell, lease, trade, or otherwise profit from an individual’s finger scan data.  Prime Flight will not disclose an employee’s finger scan data unless (a) the subject of the data consents to the disclosure, (b) disclosure is required by law, or (c) disclosure is required by a valid warrant or subpoena issued by a court of competent jurisdiction. Our vendor also has represented that it will not sell, lease, trade, or otherwise profit from the finger scan data that is created by its devices that is in its possession.   

Data Storage and Security 

Prime Flight will store, transmit, and protect from disclosure finger scan data using a reasonable standard of care. Such storage, transmission, and protection from disclosure will be performed in a matter that is the same as or more protective than the manner in which Prime Flight stores, transmits, and protects from disclosure other confidential and sensitive information.  

Retention Schedule 

Prime Flight will permanently destroy employee finger scan data within a reasonable period of time when the purpose for obtaining or collecting such data has been fulfilled.  Generally, this means within one month of an employee’s termination of employment but in no event will it be longer than three years.