Peryam & Kroll Research Corporation (“P&K”) has instituted the following biometric information privacy policy (the “Policy”).

The Illinois Biometric Information Privacy Act

The Illinois Biometric Information Privacy Act, 740 ILCS 14/1, et seq. (“BIPA”) regulates the collection, storage, use, and retention of “biometric identifiers” and “biometric information.” As defined in BIPA, “biometric identifier” means:

As also defined in BIPA, “biometric information” means

This Policy adopts the definitions of “biometric identifier” and “biometric information” in BIPA.

Purpose for Collection

To assist P&K with its timekeeping and payroll practices, P&K, its current payroll vendor B2E Solutions Inc. (“B2E”), and any other payroll, human resources, time and labor, and/or workforce management vendor that P&K contracts or may contract in the future with, may collect biometric identifiers and/or biometric information from P&K’s employees. Such biometric identifiers and/or biometric information will be collected, stored, and used solely for employee identification, fraud prevention, and other timekeeping and employment-based purposes.

In accordance with Section 15 of BIPA, P&K will not sell, lease, trade or otherwise profit from an employee’s biometric identifiers or biometric information. P&K will not disclose, redisclose, or otherwise disseminate an employee’s biometric identifiers or biometric information unless:

  1. The employee consents to the disclosure;
  2. The disclosure completes a financial transaction requested or authorized by the employee or his or her legal representative;
  3. The disclosure is required by state or federal law or municipal ordinance; or
  4. The disclosure is required pursuant to a valid warrant or subpoena issued by a court or subpoena issued by a court of competent jurisdiction.

Consent

In accordance with Section 15 of BIPA, employees of P&K will be asked to sign a consent form authorizing P&K, B2E, and any other payroll, human resources, time and labor, and/or workforce management vendor that P&K contracts with, to use his or her biometric identifiers and biometric information for the purpose discussed above.

Retention Schedule

In accordance with Section 15 of BIPA, in the event P&K does in fact collect an employee’s biometric identifiers and/or biometric information, P&K will retain such employee’s biometric identifiers and biometric information for a period of time from P&K’s initial collection of same to, at the latest, immediately after a 90 day period during which such employee does not clock in on a P&K timekeeping device, at which point in time P&K will destroy all biometric identifiers and biometric information in its possession relating to such employee. In the event an employee and P&K’s employment relationship is terminated, pursuant to the employee’s issuance of a written resignation letter or by P&K’s communicated decision to terminate the employee, P&K will immediately destroy all biometric identifiers and biometric information in its possession relating to such employee.

This retention schedule may not apply should P&K receive a valid warrant or subpoena issued by a court of competent jurisdiction directing production of an employee’s biometric identifiers and biometric information.

Data Storage

In accordance with Section 15 of BIPA, P&K shall use a reasonable standard of care to store, transmit and protect from unpermitted disclosure any biometric identifiers and biometric information collected, and shall further store, transmit, and protect from unpermitted disclosure all such biometric information in a manner in which, or more protective than that in which P&K currently stores, transmits, and protects other confidential and sensitive information, including other personal information that can be used to uniquely identify an employee.