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VANEE FOODS EMPLOYEE TIMEKEEPING/DOOR ENTRY SYSTEMS POLICY

Purpose:  This policy details the established procedures for the use, protection, transmission, storage, disclosure, and destruction by Vanee Foods Company (also referred to as “Vanee” or the “Company”) of certain data generated when employees use Vanee’s timeclocks and/or door entry systems that require scanning of an employee hand. Vanee uses this data for the purpose of ensuring that employees are accurately paid for all hours worked in connection with Vanee’s payroll processes and for a secured system to gain access to the building. Vanee’s policy is to protect this data (which is described below) in accordance with the Illinois Biometric Information Privacy Act, even if that law does not cover this data.

A copy of this policy will be made available to all affected individuals, is distributed upon request, is contained in the Employee Handbook, and is publicly posted on Vanee’s webpage at www.vaneefoodservice.com. 

Timeclocks / Building Access Information Derived From Employee Hand Scans:  Vanee uses timeclocks and a separate door access system. The timeclocks are provided by its third-party vendor, Midwest Time Recorder, but they do not store any data relating to the timeclocks. Attendance on Demand is the software vendor for the timeclocks and it hosts the data bases for the information collected from the timeclocks. As explained by the vendor(s), the timeclocks work with the hand reader shining a light on the employee’s hand creating a silhouette, similar to a flashlight casting a shadow of a hand. Using that silhouette, the timeclocks take geometric measurements of the hand (lengths, widths, areas, and heights), which are then “compressed” by a mathematical formula or algorithm resulting in a 9-byte numerical template (“Template”). That Template is stored by Attendance on Demand and then used for comparison each time a user clocks in or out using the timeclocks. The door access system uses a separate, but similar process for scanning the hand and creating a Template. The vendor for the door access system is Allegion/Schlage HandNet and the Template data for that system is stored by Vanee. No images of hands, palm prints, fingerprints or fingers are collected or stored in either system, at initial enrollment or thereafter.

Use, Protection, Transmission, Storage, Disclosure, and Destruction of Employee Hand Scan Template Data:  The Templates related to employee hand scans are stored as described above for each system, and, to Vanee’s understanding, on the Attendance on Demand backup systems. Vanee and/or its vendors will protect the Templates using a reasonable standard of care for its industry and in a manner that is the same or exceeds the standards used to protect other confidential and sensitive information of employees. Vanee will not sell, lease, trade, or otherwise profit from any information derived from or related to Templates. Vanee will not disclose or disseminate data derived from or related to Template data unless: (a) written consent is obtained from the employee prior to the disclosure; (b) disclosure is necessary to make a financial transaction requested or authorized by the employee; or (c) disclosure is required by law, including by a lawful warrant or subpoena.

Our vendor(s) have represented that they do not sell, lease, trade, or profit from any data derived from or related to Template data, that they will not disclose or disseminate this data (except under the circumstances identified above), and that they use reasonable standards of care within its industries for any storage, transmittal, or protection of such data. 

Any employee Template stored on Vanee’s network or equipment for the door entry system, including data stored on backup systems, if any, will be permanently destroyed within approximately 30 days of when an employee’s employment terminates or when the purpose for which the data was collected ceases to apply, whichever occurs earlier.

With regard to the timekeeping system, our vendor reports that it will promptly and permanently destroy any employee Template data once the employee is no longer enrolled in its timekeeping system or upon the request of Vanee, which occurs within 30 days of the employee no longer being employed by Vanee or no longer using the timeclock for any other reason, whichever occurs earlier. Our timekeeping vendor has posted its Biometric Information Privacy Policy at www.attendanceondemand.com.

If you have any questions about this policy, please contact Human Resources. 

 

JOSEPH’S FOOD PRODUCTS EMPLOYEE TIMEKEEPING/DOOR ENTRY SYSTEMS POLICY

Purpose:  This policy details the established procedures for the use, protection, transmission, storage, disclosure, and destruction by Joseph’s Food Products Company, Inc. (also referred to as “Joseph’s” or the “Company”) of certain data generated when employees use Joseph’s timeclocks and/or door entry systems that require scanning of an employee hand. Joseph’s uses this data for the purpose of ensuring that employees are accurately paid for all hours worked in connection with Joseph’s payroll processes and for a secured system to gain access to the building. Joseph’s policy is to protect this data (which is described below) in accordance with the Illinois Biometric Information Privacy Act, even if that law does not cover this data.

A copy of this policy will be made available to all affected individuals, is distributed upon request, and is made publicly available and posted in Joseph’s Employee Handbook. If, in the future, data related to employees’ hand scans is obtained or used for any additional purposes than those stated in this policy, or if such information is retained longer than the time periods identified in this policy, Joseph’s will revise this Policy and make it available to affected employees, in addition to updating any public posting. 

Timeclocks / Building Access Information Derived From Employee Hand Scans:  Joseph’s uses timeclocks and a separate door access system. The timeclocks are provided by its third-party vendor, Midwest Time Recorder, but they do not store any data relating to the timeclocks. Attendance on Demand is the software vendor for the timeclocks and it hosts the data bases for the information collected from the timeclocks. As explained by the vendor(s), the timeclocks work with the hand reader shining a light on the employee’s hand creating a silhouette, similar to a flashlight casting a shadow of a hand. Using that silhouette, the timeclocks take geometric measurements of the hand (lengths, widths, areas, and heights), which are then “compressed” by a mathematical formula or algorithm resulting in a 9-byte numerical template (“Template”). That Template is stored by Attendance on Demand and then used for comparison each time a user clocks in or out using the timeclocks. The door access system uses a separate, but similar process for scanning the hand and creating a Template. The vendor for the door access system is Allegion/Schlage HandNet and the Template data for that system is stored by Joseph’s. No images of hands, palm prints, fingerprints or fingers are collected or stored in either system, at initial enrollment or thereafter.

Use, Protection, Transmission, Storage, Disclosure, and Destruction of Employee Hand Scan Template Data:  The Templates related to employee hand scans are stored as described above for each system, and, to Joseph’s understanding, on the Attendance on Demand backup systems. Joseph’s and/or its vendors will protect the Templates using a reasonable standard of care for its industry and in a manner that is the same or exceeds the standards used to protect other confidential and sensitive information of employees. Joseph’s will not sell, lease, trade, or otherwise profit from any information derived from or related to Templates. Joseph’s will not disclose or disseminate data derived from or related to Template data unless: (a) written consent is obtained from the employee prior to the disclosure; (b) disclosure is necessary to make a financial transaction requested or authorized by the employee; or (c) disclosure is required by law, including by a lawful warrant or subpoena.

Our vendor(s) have represented that they do not sell, lease, trade, or profit from any data derived from or related to Template data, that they will not disclose or disseminate this data (except under the circumstances identified above), and that they use reasonable standards of care within its industries for any storage, transmittal, or protection of such data. 

Any employee Template stored on Joseph’s network or equipment for the door entry system, including data stored on backup systems, if any, will be permanently destroyed within approximately 30 days of when an employee’s employment terminates or when the purpose for which the data was collected ceases to apply, whichever occurs earlier.

With regard to the timekeeping system, our vendor reports that it will promptly and permanently destroy any employee Template data once the employee is no longer enrolled in its timekeeping system or upon the request of Joseph’s, which occurs within 30 days of the employee no longer being employed by Joseph’s or no longer using the timeclock for any other reason, whichever occurs earlier. Our timekeeping vendor has posted its Biometric Information Privacy Policy at www.attendanceondemand.com.

If you have any questions about this policy, please contact Human Resources.