Background and Purpose
As part of its timekeeping process, Dematic uses time clocks at certain locations that are equipped with finger scan devices. The device scans an employee’s or temporary worker’s finger or fingers each time they enter or leave the work area. Dematic uses the finger scan data, which may be considered “biometric data,” to create a record of each employee’s or temporary worker’s working time and attendance, and to ensure that each person is paid correctly for the time they work. Dematic acquired these devices and the related software from Kronos Inc., a third-party vendor.
Dematic, its vendors, and/or the licensor of Dematic’s time and attendance software will not sell, lease, trade, or otherwise profit from the biometric data collected; provided, however, that Dematic’s vendors and the licensor of Dematic’s time and attendance software may be paid for products or services used by Dematic that utilize such biometric data.
Use, Disclosure, and Protection of Finger Scan Data
Dematic will use finger scan data only for the purposes stated in this Policy and for business activities directly related to achieving those purposes. Dematic will not sell, lease, trade, or otherwise profit from an employee’s or temporary worker’s finger scan data. Dematic will not disclose, provide access to, or otherwise disseminate any finger scan data other than as stated in this Policy, unless:
- The employee or temporary worker consents to such disclosure;
- The disclosed data completes a financial transaction requested or authorized by the employee or temporary worker;
- The disclosure is required by state or federal law or municipal ordinance; or
- The disclosure is required by a valid warrant or subpoena issued by a court of competent jurisdiction.
Dematic stores each employee’s or temporary worker’s finger scan data in secure password-protected electronic files at a Dematic site, or in secure password-protected electronic storage space provided by Kronos. The finger scan data files and the applicable passwords are accessible only by those authorized Dematic or Kronos personnel who are responsible to manage or use the data for timekeeping and payroll purposes and who have signed agreements to maintain the confidentiality of the data as required by this Policy.
Retention and Destruction
Dematic will retain an employee’s or temporary worker’s finger scan data until the end of his or her employment or engagement with Dematic, or until the employee or temporary worker is no longer in a Dematic location or position that requires the use of a finger scan device for timekeeping. Within 180 days of either of those events, Dematic will permanently destroy (and, if applicable, will require Kronos to destroy) the employee’s or temporary worker’s finger scan data. Dematic will comply with these retention and destruction requirements unless a court of competent jurisdiction issues a valid warrant or subpoena that requires Dematic to deviate from these requirements.