Student Biometric Information Privacy Policy

Paul Mitchell The School East Bay records attendance in clock hours. To ensure proper clock hours are credited, students are required to clock in and out utilizing a biometric scanner in accordance with the Course Key policy. Biometric scanners are computer-based systems that scan a student’s finger or facial identifier for purposes of identification. The computer system extracts unique data points and creates a unique mathematical representation used to verify a person’s identity. Paul Mitchell The School East Bay or its vendors may collect, retain, and use biometric data for the purpose of identifying students when recording clock hours.

Biometric Data Defined

In general, biometric data is “biometric identifiers” and “biometric information” as defined below. “Biometric identifier” means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. Biometric identifiers do not include writing samples, written signatures, photographs, human biological samples used for valid scientific testing or screening, demographic data, tattoo descriptions, or physical descriptions such as height, weight, hair color, or eye color.

“Biometric information” means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier used to identify an individual. Biometric information does not include information derived from items or procedures excluded under the definition of biometric identifiers.

Purpose for Collection of Biometric Data

The School does not collect or store biometric data. At this time, the School’s third-party time clock vendor may collect and store an individual’s biometric identifier (for example, fingerprint or facial identifiers), solely for identification in connection with the use of the biometric time clock. The School’s third-party time clock vendor will retain biometric data of an only for so long as the person is an enrolled student. The biometric data shall be permanently removed from the records of the School’s vendors and licensors in accordance with the retention schedule set forth herein.

Disclosure and Authorization

Each student will be required to sign the Release and Consent to Use of Biometric Data as a condition of his/her enrollment with the School. The School and its time clock vendors will not sell, lease, trade, or otherwise profit from students’ biometric data; provided, however, that the School’s time clock vendor will be paid for products or services used by the School that utilize such biometric data.

The School will not disclose or disseminate any biometric data to anyone other than its time clock vendors without first obtaining student’s written consent to such disclosure or dissemination unless disclosure or redisclosure is required by state or federal law or municipal ordinance or required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.

Retention Schedule

The School shall retain a student’s biometric data only until, and shall require that its time clock vendors permanently destroy such data when, the first of the following occurs:

  1. Within thirty (30) days after the initial purpose for collecting or obtaining such biometric data has been satisfied, such as the withdrawal or graduation of a student; or
  2. Within 3 years of the student’s last interaction with the School.

Data Storage

The School and its time clock vendors shall 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 way the School or its time clock vendors transmit and protect 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 driver’s license numbers and social security numbers.