Biometric Information Privacy Policy
DISCLOSURE
Kolcraft will not disclose or disseminate any biometric data to anyone other than its time clock supplier and ADP without/unless:
- First obtaining written employee consent to such disclosure or dissemination;
- The disclosed data completes a financial transaction requested or authorized by the employee;
- Disclosure 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.
RETENTION SCHEDULE
Kolcraft will retain employee biometric data only until, and will request its supplier and ADP destroy such data when, the first of the following occurs;
- The initial purpose for collecting or obtaining such biometric data has been satisfied, such as the termination of the employee’s employment with the Company, or the employee moves to a role within the Company for which the biometric data is not used; or
- Within 3 years of the Employee’s last interaction with Company.
DATA STORAGE
Kolcraft will use a reasonable standard of care to store, transmit and protect from disclosure any paper or electronic biometric data collected. Such storage, transmission, and protection from disclosure shall be performed in a manner that is the same as or more protective than the manner in which the Kolcraft stores, transmits and protects from disclosure other confidential and sensitive information, including personal information that can be used to uniquely identify an individual or an individual’s account or property, such as genetic markers, genetic testing information, account numbers, PINS, driver’s license numbers and social security numbers.
PUBLIC ACCESS
A copy of this policy will be made available to all employees who are requested to provide consent per this policy and posted in Kolcraft’s facility that utilizes biometric timeclocks. A copy of this policy will also be made available to the public at: https://www.kolcraft.com/privacy-policy/
Effective 1/1/20
