Biometric Data Policy

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Purpose

The purpose of this policy is to define the policy and procedures for the collection, use, safeguarding, storage, retention, and destruction of biometric data. It is the policy of Domino's Pizza LLC and its parents, subsidiaries, and affiliates (the "Company") to protect, use, and store biometric data in accordance with all applicable laws including, but not limited to, the Illinois Biometric Information Privacy Act and the Colorado Privacy Act (C.R.S. §6-1-1306).

Biometric Data Defined

As used in this policy, biometric data includes "biometric identifiers" and "biometric information."

"Biometric identifier" means data generated by the technological processing, measurement, or analysis of an individual's biological, physical, or behavioral characteristics, including but not limited to a retina or iris scan, fingerprint, voiceprint, scan of hand or face geometry, facial mapping, facial templates, or other unique biological, physical, or behavioral patterns or characteristics used to identify a specific individual, which can be processed for identification. Biometric identifiers do not include writing samples, written signatures, photographs (unless as described below), 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 identifiers do not include information captured from a patient in a health care setting or information collected, used, or stored for health care treatment, payment, or operations under the federal Health Insurance Portability and Accountability Act of 1996.

"Biometric information" or "Biometric Data" means any information, regardless of how it is captured, converted, stored, or shared, based on an individual's biometric identifier that are used, or intended to be used, singly or in combination with each other or with other Personal Data, to identify an individual. Unless such data is used for identification purposes, "Biometric information" or "Biometric Data" does not include (a) a digital or physical photograph, (b) an audio or video recording, or (c) any data generated from a digital or physical photograph or an audio or video recording or other information derived from items or procedures excluded under the definition of biometric identifiers.

"Personal Data" (a) means information that is linked or reasonably linkable to an identified or identifiable individual; and (b) does not include de-identified data or publicly available information.

The Company's Collection of Biometric Data

The Company and its third-party vendor, UKG, which provides the Company's time and attendance software, collect, store, and use biometric data for the purpose of identifying employees and recording time entries when utilizing the Company's biometric timeclocks or timeclock attachments.

Biometric timeclocks are computer-based systems that scan an employee's finger or hand for purposes of identification. The computer system extracts unique data points and creates a unique mathematical representation used to verify the employee's identity; for example, when the employee arrives at or departs from the workplace.

This data is collected, stored, and used to identify employees and record time.

Disclosure

To the extent that the Company, and its third-party vendor UKG, collect, capture, or otherwise obtain biometric data relating to an employee, the Company:

  1. Will inform the employee about the collection, storage, and use of such biometric data;
  2. Will inform the employee of the specific purpose and length of time for which the biometric data is being collected, stored, and used;
  3. Will receive a written release executed by the employee (or his/her legally authorized representative) authorizing the Company, its third-party vendor(s), and/or the licensor(s) of the Company's time and attendance software to collect, store, and use the employee's biometric data for the specific purposes disclosed by the Company, and for the Company to provide such biometric data to its third-party vendor UKG; and

  4. Will not disclose, redisclose, or otherwise disseminate an employee's biometric data unless:

    • The employee or his/her legally authorized representative consents to such disclosure or redisclosure;
    • The disclosure or redisclosure completes a financial transaction requested or authorized by the employee or his/her legally authorized representative;
    • The disclosure or redisclosure is required by federal, state, or local law; or
    • The disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.

Retention Schedule

The Company will retain employee biometric data only until, and will request that its third-party vendor UKG destroy such data when the first of the following occurs, unless such destruction is prohibited by law:

  1. The date the initial purpose for collecting or obtaining such biometric data has been satisfied, such as the separation of the employee's employment with the Company or the Company ceasing to use biometric data; or
  2. Within 24 months' of the employee's last interaction with the Company; or
  3. Within 45 days of the Company's determination that storage of the biometric identifier is no longer necessary, adequate, or relevant to the processing purpose

Data Storage, Transmission, and Protection

The Company will store, transmit, and protect biometric data using a reasonable standard of care. Such storage, transmission, and protection from disclosure will be performed in a manner that is the same as or more protective than the manner in which the Company stores, transmits, and protects from disclosure other confidential and sensitive information of the Company and its employees. The Company maintains a protocol for responding to data security incidents that could compromise the security of either biometric identifiers or biometric data, and will notify you in the event of any such data security incident.

Questions or Accommodations

If you have any questions or want to request an accommodation based on religious, cultural, medical, or other reasons, contact your PeopleFirst representative or the Team Member Service Center at (877) 921-8326.