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. Such vendors and products that Roehl Transport uses are Lytx Inc.'s (“Lytx”) DriveCam Event Recorder (“DriveCam”), Netradyne Inc.’s (“Netradyne”) Driver.i system (“Driver.i”) and Motive Technologies, Inc.’s (“Motive”) Dashcam Technology (“Dashcam”). Roehl contracts with Lytx, Netradyne and Motive to provide the DriveCam, Driver.i and Dashcam. The DriveCam, Driver.i and Dashcam 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, Driver.i and Dashcam captures video footage of individuals seated in the driver and passenger seats of Roehl Transport trucks. The video footage data collected by DriveCam, Driver.i and Dashcam 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 “the Data”). The 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.
The Dashcam uses driver-facing Dashcams and will scan and analyze video of the interior of the vehicle in which the Dashcam is mounted. The Dashcam will extract data based on the objects and occupants inside the vehicle (in some cases, facial and body measurements and locations of the occupants). Where the Dashcam is used for identification or potential identification (e.g., Motive Face Match), the Data extracted from the video collected by the Dashcam will be compared to face data templates (the “Templates”) that were created and associated with individuals when those individuals first used the Dashcam or presented themselves or their photograph for scanning by Roehl Transport, Motive, or their vendors. Motive Face Match will then report whether there is a match between the occupant(s) of the vehicle and an identity associated with a Template. Where the Dashcam is used to help detect the unsafe operation of vehicles, the Data extracted from the video collected by the Dashcam will be processed by an algorithm to make inferences or determinations about the occupants of the vehicle, such as that a driver is drowsy, using a mobile device while driving, or not wearing a seatbelt. Inferences and determinations may be used to generate an alert.
Lytx, Netradyne and Motive’s technology allows Roehl Transport to use the DriveCam, Driver.i and Dashcam 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, Netradyne, and Motive’s technology enhances safety by increasing the efficacy of Lytx, Netradyne and Motive’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, Driver.i or Dashcam 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 Biometric 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 Dashcam Data collected will be disclosed to Motive and stored on Motive’s cloud servers which are accessible through a Motive account. Motive 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 Motive’s privacy practices, a copy of Motive’s privacy policy is available at https://gomotive.com/legal/privacy/ and a copy of Motive’s Biometric Data policy is available at https://gomotive.com/legal/biometric-data-collection-policy/ and https://gomotive.com/legal/biometric-services-addendum.
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.
The Dashcam uses driver-facing Dashcams and will scan and analyze video of the interior of the vehicle in which the Dashcam is mounted. The Dashcam will extract data based on the objects and occupants inside the vehicle (in some cases, facial and body measurements and locations of the occupants). Where the Dashcam is used for identification or potential identification (e.g., Motive Face Match), the Data extracted from the video collected by the Dashcam will be compared to face data templates (the “Templates”) that were created and associated with individuals when those individuals first used the Dashcam or presented themselves or their photograph for scanning by Roehl Transport, Motive, or their vendors. Motive Face Match will then report whether there is a match between the occupant(s) of the vehicle and an identity associated with a Template. Where the Dashcam is used to help detect the unsafe operation of vehicles, the Data extracted from the video collected by the Dashcam will be processed by an algorithm to make inferences or determinations about the occupants of the vehicle, such as that a driver is drowsy, using a mobile device while driving, or not wearing a seatbelt. Inferences and determinations may be used to generate an alert.
Lytx, Netradyne and Motive’s technology allows Roehl Transport to use the DriveCam, Driver.i and Dashcam 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, Netradyne, and Motive’s technology enhances safety by increasing the efficacy of Lytx, Netradyne and Motive’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, Driver.i or Dashcam 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 Biometric 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 Dashcam Data collected will be disclosed to Motive and stored on Motive’s cloud servers which are accessible through a Motive account. Motive 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 Motive’s privacy practices, a copy of Motive’s privacy policy is available at https://gomotive.com/legal/privacy/ and a copy of Motive’s Biometric Data policy is available at https://gomotive.com/legal/biometric-data-collection-policy/ and https://gomotive.com/legal/biometric-services-addendum.
Data Storage, Protection and Disclosure Policy
Roehl Transport, Lytx, Netradyne and Motive use reasonable technical, organizational, and physical safeguards intended to protect the security, confidentiality, and privacy of any Biometric Data collected by the DriveCam, Driver.i and Dashcam 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, Netradyne and Motive do not sell, lease, or trade or otherwise profit from any Biometric Data.
Roehl Transport, Lytx, Netradyne and Motive 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, Motive 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, Netradyne and Motive 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, Motive 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, Netradyne and/or Motive 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, Driver.i or Dashcam. Following the end of the driver’s employment relationship or working assignment, Roehl Transport and/or Lytx, Netradyne and Motive will permanently delete any of your Biometric Data collected by the DriveCam, Driver.i and Dashcam within a reasonable timeframe, but no later than one (1) year from the date of the driver’s last use of the DriveCam, Driver.i or Dashcam.
Roehl may indefinitely retain deidentified, anonymized, blurred, and redacted DriveCam, Driver.i or Dashcam 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, Driver.i or Dashcam 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, Driver.i or Dashcam is used, the driver must execute the “Notice and Consent Regarding Collection of Biometric Data” form.
This page was updated on: 8/5/2025