Ceridian’s Biometric Notice

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SCOPE
This notice applies to the processing of time and attendance-related information collected by finger scan timekeeping devices, Dayforce Touch, TUFF and Maximus, and shared with Ceridian by its customers, that may be considered biometric data or biometric information pursuant to certain states’ laws.

DEFINITIONS 
Ceridian’s use of the term “biometric data” within this policy does not reference any particular legal definition of that term.  Instead, Ceridian’s use of the term biometric data refers to the data collected by Ceridian’s finger scan timekeeping devices. It is the responsibility of Ceridian’s customers to determine if applicable data protection and biometric privacy laws apply to the customer’s use of Ceridian’s finger scan timekeeping devices. 

HOW WE COLLECT BIOMETRIC DATA
Ceridian collects the biometric data of its customers’ employees at the direction of its customers through the use of a Ceridian clock as part of a timekeeping system.  Ceridian’s finger scan clocks use multiple wavelengths of light to identify certain unique points on a user’s finger and then create a code associated with the user, known as a Template.  Using a proprietary algorithm, the data is converted into an alpha-numeric “Template Value.”  Each time an individual uses the clock, it creates a temporary Template Value which is compared to the user’s original Template Value.  The original Template Value is stored on the clock and it is also sent to Ceridian and stored in the application database.  Each temporary Template Value is stored only momentarily on the Ceridian clock.  

CONSENT
If consent is required to collect, store and or use the data collected by Ceridian finger scan clocks under any applicable laws, Ceridian relies on its customers to obtain such consent or determine another lawful basis for processing biometric data.  Ceridian may also obtain separate written consent for the collection, storage and/or use of this information.

HOW WE USE BIOMETRIC DATA
Ceridian processes biometric data only on behalf of and at the direction of its customers.  Ceridian’s customers may choose to use clocks to track time and attendance of their employees.

RETENTION AND DISPOSAL
Biometric data is securely stored on the Ceridian clock and in the Ceridian application database.  A user’s biometric data is deleted from the Ceridian clock when the user’s status is changed to terminated or when a badge is no longer valid. A user’s biometric data is retained in the application database until 90 days after the customer changes the user’s status to terminated or a badge is no longer valid.  Biometric data may also be stored in archives. Archived biometric data will be stored by Ceridian no longer than 3 years after the date the biometric data is deleted from the application database. 

HOW WE SHARE BIOMETRIC DATA
Ceridian does not sell, lease, trade or otherwise profit from biometric data.  Ceridian does not authorize its vendors or customers to sell, lease, trade or otherwise profit from biometric data.  

Biometric data may be accessed by Ceridian, its subsidiaries and third-party consultants to implement and manage the services of its customers.  Ceridian may share biometric data with its affiliates, in addition to its contractors, including HID Global, ARCX and Archronix for maintenance of the biometric clocks.

Ceridian will not share biometric data with any other third party unless:

  • The customer’s employee or the employee’s authorized representative provides written consent to share;
  • Disclosure is permitted or required by applicable law or is in response to subpoenas, court orders, or other legal processes. 

 

Last Updated on June 19, 2019.

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