Sample Biometric Consent Form

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The key takeaways are that AAI collects biometric data like fingerprints and hand geometry for timekeeping purposes and to grant employees access to timekeeping systems. It obtains written consent and stores, transmits, and protects the data securely and in compliance with applicable laws and standards.

According to the policy, AAI collects, stores, and uses employee biometric data for the purpose of granting employees access to AAI’s timekeeping systems and to document employees’ (i) clock in/out time(s); (ii) clock in/out location(s); and (iii) attempts/failures/errors in biometric data scans.

The definition in the policy states that biometric data can include fingerprints, voiceprints, a retina scan, scans of hand or face geometry, or other data.

AAI BIPA POLICY AND CONSENT

Purpose

This Biometric Information and Security Policy (“Policy”) defines AAI’s policy and procedures
for collection, use, safeguarding, storage, retention, and destruction of biometric data collected
by AAI and/or its vendors.

AAI uses biometric identification systems for employee timekeeping with regard to payroll.
AAI and/or its vendor(s) collects, stores, and uses employee biometric data for the purpose of
granting employees access to AAI’s timekeeping systems and to document employees’ (i) clock
in/out time(s); (ii) clock in/out location(s); and (iii) attempts/failures/errors in biometric data
scans.

Policy

AAI’s policy is to protect and store biometric data in accordance with applicable standards and
laws, including, but not limited to, the Illinois Biometric Information Privacy Act.

An individual’s biometric data will not be collected or otherwise obtained by AAI without prior
written consent of the individual. AAI will inform the employee of the reason his or her
biometric information is being collected and the length of time the data will be stored.

Definition

Biometric data means personal information stored by AAI and/or its vendor(s) about an
individual’s physical characteristics that can be used to identify that person. Biometric data can
include fingerprints, voiceprints, a retina scan, scans of hand or face geometry, or other data.

Procedure

AAI and/or its vendor(s) collects, stores, and uses biometric data for the purposes of giving
employees access to AAI’s timekeeping systems and for maintaining accurate records of
employee time.

Prior to collecting biometric data, AAI will obtain the consent of the employee. A sample
consent form is included with this policy statement.

26072802.1
AAI will not sell, lease, trade, or otherwise profit from an individual’s biometric data. AAI will
not disclose biometric data unless (a) consent is obtained, (b) disclosure is required by law, or (c)
disclosure is required by a subpoena.

AAI will store, transmit, and protect biometric data using a reasonable standard of care and in a
manner that is the same as or exceeds the standards followed in maintaining other confidential
and sensitive information.

AAI will permanently destroy an employee’s biometric data from AAI’s systems, or the systems
of AAI’s vendor(s), within a reasonable time following the employee’s termination from AAI.

In the event AAI begins collecting biometric data for any additional purpose, AAI will update
this procedure.

A copy of this policy will be made publicly available at http://www.aainvh.com/.

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26072802.1
Consent to Collection of Biometric Data

Your hand geometry or other biometric data will be collected and stored by AAI and/or its
vendor(s) for the purpose of verifying your identity for access to the AAI timekeeping system.
Your biometric data will not be disclosed by AAI without your consent unless the disclosure is
required by law or by valid legal subpoena. Your biometric data will be permanently deleted
from AAI’s systems within a reasonable time after your employment with the company ends, not
to exceed 3 years from that date. A copy of AAI’s Biometric Information and Security Policy is
available upon request, is included in the AAI employee handbook, and is posted at
http://www.aainvh.com/.

By signing below, you consent to AAI’s collection, use, and storage of your hand geometry or
other biometric data for the above defined purpose.

Team Member Signature Date

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26072802.1

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