JFS MILLING, INC. BIOMETRIC INFORMATION AND
IDENTIFIERS RETENTION AND DESTRUCTION POLICY
JFS Milling, Inc. (“Company”) utilizes drive-cams in certain of its vehicles to protect the Company and its drivers, to enhance its driver’s job performance, to increase driver safety and the safety of the general public, and to increase the situational awareness of its drivers. It is presently using a Lytx MV+AI system (the “MV+AI System”) and it may use other drive-cam systems in the future. These drive-cams and their associated hardware and software are or may be collecting, storing, using and transmitting to third parties the Biometric Identifiers and/or Biometric Information of Company employees. “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.
Lytx has indicated that the MV+AI System does not collect biometric identifiers or information. Assuming that the drive-cams utilized by the Company are collecting, storing, using or transmitting to third parties the Biometric Identifiers and/or Information of Company employees, any such Biometric Identifier or Information does not leave the MV+AI System device’s memory and it is immediately and permanently destroyed by the MV+AI System, once the prediction of a distracted or prohibited driving behavior has been made or shortly thereafter. In the event that any of an employee’s Biometric Information or Identifiers are not immediately destroyed and deleted by the MV+AI System or other drive cam in use by Company, at or shortly after their initial collection by the drive cam system, the employee’s Biometric Information or Identifiers will be permanently destroyed or overwritten in the drive cam’s system memory during the next use of the drive cam system or within 3 years of the date of the termination of your employment with Company or within 3 years from the date the employee last drove a Company vehicle containing a drive-cam.
The permanent deletion of any Biometric Identifier or Biometric Information is performed by the MV+AI System itself which continually overwrites and thereby permanently deletes data in the device’s system memory of a Company employee; or alternatively shall be performed by Company in a manner consistent with best practices in the data security industry to ensure permanent deletion of any Biometric Identifier or Biometric Information of the Company employee.
