This policy is intended to advise employees of the nature and extent any system in use by Incredible Technologies, Inc. (the “Company”) uses information which may be considered biometric information or biometric identifiers subject to the Illinois Biometric Information Privacy Act (“BIPA”), 740 ILCS 14/1, et seq.
The Company is engaged in the highly regulated gaming industry and is required to obtain licenses to operate gaming in various jurisdictions. In order to comply with gaming regulatory licensing requirements, gaming applications are required to be submitted with fingerprints of employees holding certain positions. The Company formerly outsourced this service and maintained a hard copy of licensed employees’ fingerprints. Effective August 8, 2023, the Company will obtain necessary employee fingerprints through a digital scan, which can then be printed and signed by the employees, and submitted with the licensing applications.
Disclosure
- The fingerprints of the employees identified for the licensing purpose above is collected, used, stored, disclosed, or disseminated to the Company through the collection process above. The fingerprints will also be submitted to the appropriate regulatory agencies to which the application is submitted, and from which the licensing will be obtained. The Company will not disclose, redisclose or disseminate this information to anyone outside the Company other than the regulatory agency for the purposes identified above, unless required by law.
- The Company will not sell, lease, trade, or otherwise profit from the stored image of the employee’s fingerprints.
Retention and Destruction Guidelines
Fingerprints collected prior to the use of the new system, and on a going forward basis, are stored in the Company’s personnel file, as well as electronically within the Company, and are maintained for the employee for the duration of the employee’s employment with the Company.
Within 30 days of the date of the employee’s termination of employment, the Company will permanently destroy the fingerprints.
Storage, Transmission and Protection
The Company shall use a reasonable standard of care to store, transmit and protect from disclosure the stored fingerprint. Such storage, transmission, and protection from disclosure shall be performed in a manner that is the same as the manner in which the Company stores, transmits and protects from disclosure confidential and sensitive information, such as account numbers, PINs, driver’s license numbers and social security numbers