​SUMMIT STAFFING, INC.’S BIOMETRIC INFORMATION RETENTION POLICY

1. Purpose
1.1 To establish Summit Staffing, Inc.’s (“Summit Staffing”) retention schedule and guidelines for the destruction of biometric identifiers and biometric information.

2. Definitions
2.1 “Biometric identifier” means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. This policy incorporates the definition of biometric identifier utilized by the Illinois Biometric Information Privacy Act, 740 ILCS 14/10.

2.2 “Biometric information” means any information, regardless of how it is captured,
converted, stored, or shared, based on an individuals’ biometric identifier used to identify an individual. This policy incorporates the definition of biometric information utilized by the Illinois Biometric Information Privacy Act, 740 ILCS 14/10. Unless specifically stated otherwise, the term “biometric information” as used in this Policy shall refer to both biometric identifiers and biometric information as defined in this section.

3. Retention Schedule and Guidelines
3.1 Summit Staffing’s policy is to use biometric information in accordance with all
applicable laws, including the Illinois Biometric Information Privacy Act, 740 ILCS 14/1, et seq.

3.2 Summit Staffing will ensure that fingerprint and/or hand geometry data and/or
facial recognition data will be destroyed upon the earliest of the following: (1) as soon as is reasonably possible – usually 30 days – after the employee is no longer assigned to the client utilizing the device or no longer a Summit Staffing employee (i.e., within 30 days after the purpose for which the biometric data was taken ends); or (2) within three years of the employee’s last interaction with Summit Staffing or the client utilizing the device.

3.3 Summit Staffing will store, transmit, and protect from disclosure all biometric
information using the reasonable standard of care within the industry and in the same manner as Summit Staffing stores, transmits, and protects other confidential and sensitive information.

3.4 Summit Staffing will keep this policy publicly available on its website.