Biometric Data Collection and Retention Policy
Biometric Data Collection and Retention Policy
Roehl Transport, Inc. (“Roehl Transport”) has adopted this Biometric Data Collection and Retention Policy (“Policy”) to address how Roehl Transport may collect, store, use, receive, access, capture, obtain, retain, disclose, and permanently destroy data used in connection with multiple vendors to provide, manage, and operate certain cameras on its fleet. Two such vendors and products that Roehl Trasnport uses are Lytx Inc.'s (“Lytx”) DriveCam Event Recorder (“DriveCam”) and Netradyne Inc.’s (“Netradyne”) Driver.i system (“Driver.i”). Roehl contracts with Lytx and Netradyne to provide the DriveCam and Driver.i. The DriveCam or Driver.i may collect Biometric Data (as defined below) for certain purposes described below. This Policy is intended to comply with the Illinois Biometric Information Privacy Act (“BIPA”), the Texas Capture or Use of Biometric Identifier Act (“CUBI”) and any other applicable laws, and explains what that means for you, and how you consent to Roehl Transport’s activities described in this Policy.
Definitions
The DriveCam and Driver.i captures video footage of individuals seated in the driver and passenger seats of Roehl Transport trucks. The video footage data collected by DriveCam and Driver.i may include a facial, retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry or other physiological traits used to identify an individual (collectively referred to herein as “DriveCam and Driver.i Data”). DriveCam and Driver.i Data may constitute “Biometric Data.” As used in this Policy, Biometric Data is defined to include “biometric identifiers” or “biometric information” as defined in BIPA and any other applicable state and federal laws.
Data Collection and Purpose
The DriveCam, which consists of cameras and software technology, is used by Roehl Transport to manage its fleet operations and improve driver safety. The DriveCam system includes both a road-facing camera to capture video footage of critical events, along with an inward facing camera. The DriveCam’s inward facing camera relies on facial and voice recognition technology that is designed to identify drivers and detect distracted driver behavior. The facial recognition technology integrated within the inward facing camera operates, in part, by scanning a driver’s face geometry and using the driver’s voiceprints.
The Driver.i system includes both a road-facing camera and an inward facing camera to capture video footage of critical events. The Driver.i’s inward facing camera relies on facial and voice recognition technology that is designed to identify drivers and detect distracted driver behavior. Driver.i applies certain processing and artificial intelligence techniques to the data collected from the cameras to determine whether the driver of the vehicle in which it is installed is alert, focused, wearing their seatbelt, and whether they are engaging in unsafe driving behavior, such as distracted driving (for example, by talking on their cell phone, reading or sending text messages, or otherwise not paying attention to the road ahead of them). The processing supporting the Driver.i system’s features detects head orientation, location, whether the driver is holding an object such as a smartphone, as well as blinking, yawning, and whether the driver appears drowsy.
Both Lytx and Netradyne’s technology allows Roehl Transport to use the DriveCam and Driver.i Data to confirm that the dash cameras are not obstructed or blocked, conducting safety training and counseling, analyzing driving and driver performance, recognizing safe performance, improving safety protocols, defending against claims and litigation, investigating personnel actions, and analyzing risk and driving events. Using the features on Lytx and Netradyne’s technology enhances safety by increasing the efficacy of Lytx and Netradyne’s driver-based insights, improving driver safety and efficiency, and also helping Roehl Transport to maintain accurate logs of its operations. Certain data collected from DriveCam or Driver.i may be considered Biometric Data under Illinois or Texas Law.
The DriveCam Data collected will be disclosed to Lytx and stored on Lytx’s cloud servers which are accessible through a Lytx account. Lytx will have access to the data to perform the functions and provide the services pursuant to the executed services agreement with Roehl Transport. For more information about Lytx’s privacy practices, a copy of Lytx’s privacy policy is available at https://www.lytx.com/en-us/privacy-policy.
The Driver.i Data collected will be disclosed to Netradyne and stored on Netradyne’s cloud servers which are accessible through a Netradyne account. Netradyne will have access to the Biometric Data to perform the functions and provide the services pursuant to the executed services agreement with Roehl Transport. For more information about Netradyne’s privacy practices, a copy of Netradyne’s privacy policy is available at https://www.netradyne.com/privacy-policy and a copy of Netradyne’s Biometric Data policy is available at https://www.netradyne.com/biometric-data-privacy-policy.
The Driver.i system includes both a road-facing camera and an inward facing camera to capture video footage of critical events. The Driver.i’s inward facing camera relies on facial and voice recognition technology that is designed to identify drivers and detect distracted driver behavior. Driver.i applies certain processing and artificial intelligence techniques to the data collected from the cameras to determine whether the driver of the vehicle in which it is installed is alert, focused, wearing their seatbelt, and whether they are engaging in unsafe driving behavior, such as distracted driving (for example, by talking on their cell phone, reading or sending text messages, or otherwise not paying attention to the road ahead of them). The processing supporting the Driver.i system’s features detects head orientation, location, whether the driver is holding an object such as a smartphone, as well as blinking, yawning, and whether the driver appears drowsy.
Both Lytx and Netradyne’s technology allows Roehl Transport to use the DriveCam and Driver.i Data to confirm that the dash cameras are not obstructed or blocked, conducting safety training and counseling, analyzing driving and driver performance, recognizing safe performance, improving safety protocols, defending against claims and litigation, investigating personnel actions, and analyzing risk and driving events. Using the features on Lytx and Netradyne’s technology enhances safety by increasing the efficacy of Lytx and Netradyne’s driver-based insights, improving driver safety and efficiency, and also helping Roehl Transport to maintain accurate logs of its operations. Certain data collected from DriveCam or Driver.i may be considered Biometric Data under Illinois or Texas Law.
The DriveCam Data collected will be disclosed to Lytx and stored on Lytx’s cloud servers which are accessible through a Lytx account. Lytx will have access to the data to perform the functions and provide the services pursuant to the executed services agreement with Roehl Transport. For more information about Lytx’s privacy practices, a copy of Lytx’s privacy policy is available at https://www.lytx.com/en-us/privacy-policy.
The Driver.i Data collected will be disclosed to Netradyne and stored on Netradyne’s cloud servers which are accessible through a Netradyne account. Netradyne will have access to the Biometric Data to perform the functions and provide the services pursuant to the executed services agreement with Roehl Transport. For more information about Netradyne’s privacy practices, a copy of Netradyne’s privacy policy is available at https://www.netradyne.com/privacy-policy and a copy of Netradyne’s Biometric Data policy is available at https://www.netradyne.com/biometric-data-privacy-policy.
Data Storage, Protection and Disclosure Policy
Roehl Transport, Lytx and Netradyne use reasonable technical, organizational, and physical safeguards intended to protect the security, confidentiality, and privacy of any Biometric Data collected by the DriveCam and Driver.i against unauthorized access, modification, or destruction, in no event less than the reasonable standards of care within their industries for any storage, transmittal, or protection from disclosure of any Biometric Data they may possess, and in a manner that is the same as or more protective than the way they store, transmit and protect other similar confidential and sensitive information. Roehl Transport, Lytx and Netradyne do not sell, lease, or trade or otherwise profit from any Biometric Data.
Roehl Transport, Lytx and Netradyne will not disclose any Biometric Data unless the disclosure: (1) is made pursuant to the written consent from the driver(s); (2) completes a financial transaction requested or authorized by the driver(s); (3) is required by state or federal law, or municipal ordinance; or (4) is required pursuant to a valid subpoena or warrant issued by a court of competent jurisdiction.
Additionally, Roehl Transport, Lytx, Netradyne, and Roehl Transport’s affiliates, subcontractors, and licensors may have access to Biometric Data to store such data, delete/maintain backup copies, and/or to service the systems, drives, or databases on which the Biometric Data is collected, used, or stored.
Roehl Transport, Lytx and Netradyne will not disclose any Biometric Data unless the disclosure: (1) is made pursuant to the written consent from the driver(s); (2) completes a financial transaction requested or authorized by the driver(s); (3) is required by state or federal law, or municipal ordinance; or (4) is required pursuant to a valid subpoena or warrant issued by a court of competent jurisdiction.
Additionally, Roehl Transport, Lytx, Netradyne, and Roehl Transport’s affiliates, subcontractors, and licensors may have access to Biometric Data to store such data, delete/maintain backup copies, and/or to service the systems, drives, or databases on which the Biometric Data is collected, used, or stored.
Retention and Destruction of Information/Data
A driver’s Biometric Data is collected, captured, stored, obtained, retained, or used by Roehl Transport, Lytx and/or Netradyne for 30 days, unless subject to a longer retention period for legal purposes, such as pending or potential litigation and personnel actions, but no longer than one (1) year from the date of the driver’s last use of the DriveCam or Driver.i. Following the end of the driver’s employment relationship or working assignment, Roehl Transport and/or Lytx and Netradyne will permanently delete any of your Biometric Data collected by the DriveCam within a reasonable timeframe, but no later than one (1) year from the date of the driver’s last use of the DriveCam or Driver.i.
Roehl may indefinitely retain deidentified, anonymized, blurred, and redacted DriveCam or Driver.i Data that does not identify or permit the identification of a driver or any other individual (collectively, “Training Data”) solely for the internal purpose of training and teaching other drivers instructional lessons on safe vehicle operation. For the avoidance of doubt, before any Training Data is retained for internal training purposes, Roehl will apply facial blurring or redaction to ensure that the Training Data does not contain any Biometric Data or personally identifying information, and that no individual can be identified from the Training Data.
Roehl may indefinitely retain deidentified, anonymized, blurred, and redacted DriveCam or Driver.i Data that does not identify or permit the identification of a driver or any other individual (collectively, “Training Data”) solely for the internal purpose of training and teaching other drivers instructional lessons on safe vehicle operation. For the avoidance of doubt, before any Training Data is retained for internal training purposes, Roehl will apply facial blurring or redaction to ensure that the Training Data does not contain any Biometric Data or personally identifying information, and that no individual can be identified from the Training Data.
Consent Form
Before a driver begins or continues its contract or business relationship with Roehl Transport in a role for which the DriveCam or Driver.i is used, the driver must execute the “Notice and Consent Regarding Collection of Biometric Data” form.
This page was updated on: 7/11/2025