Biometric Data Collection and Retention Policy
“Biometric Data” as used in this Policy includes: video footage (facial, retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry or other physiological traits used to identify an individual). This data may include biometric identifiers or biometric information.
Data Collection and Purpose
Roehl Transport uses Lytx Inc.'s (“Lytx”) DriveCam Event Recorder (“DriveCam”) which consists of cameras and software technology to manage our fleet and improve driver safety. The Lytx DriveCam system includes both a road-facing camera to capture video footage of critical events, along with an inward facing camera. Lytx’s DriveCam, including its inward facing camera, relies on facial and voice recognition technology to identify drivers and driver behavior. The facial recognition technology operates, in part, through scans of a driver’s face geometry and use of voiceprints. Lytx's technology allows Roehl Transport to use this data to confirm that the Lytx DriveCam dash cameras are not obstructed or blocked, safety training and counseling, analyze driving and driver performance, improve safety, defense of claims and litigation, investigations related to personnel actions, analyze risk and to analyze driving events. Using the features on Lytx's DriveCam enhances safety by increasing the efficacy of Lytx's driver-based insights, improve driver safety and efficiency, and also helps Roehl Transport to maintain accurate logs of our operations.
Data Storage, Protection and Disclosure Policy
Roehl Transport’s policy is to protect and store the information/data in accordance with applicable laws and regulations. Specifically, Roehl Transport shall use a reasonable standard of care to store, transmit and protect from disclosure any information/data collected. Such storage, transmission and protection from disclosure shall be performed in a manner that is the same as or more protective than the manner in which Roehl Transport stores, transmits and protects from disclosure other confidential and sensitive information, including personal information that can be used to uniquely identify an individual such as social security numbers.
Information/data collected from drivers using Lytx’s DriveCam dash cameras will not be disclosed to parties other than Roehl Transport or Lytx, except in the following circumstances: (1) after Roehl Transport obtains appropriate written consent from the driver(s); (2) when disclosure completes a financial transaction requested or authorized by the driver(s); (3) when disclosure is required by federal, state, or local law; or (4) when disclosure is required by a valid subpoena or warrant issued by a court. Within Roehl Transport, the information/data may be shared with only those employees who have a need to know for a specific business purpose.
Retention and Destruction of Information/Data
Roehl Transport will retain the information/data during the time that an individual is employed by or contracted with Roehl Transport in a role for which the Lytx DriveCam is used for 30 days and is accessible to Roehl Transport during that time unless subject to a longer retention period for legal purposes, such as pending or potential litigation and personnel actions. Roehl Transport and Lytx will permanently delete your Biometric Data within a reasonable time after the termination of your employment or contract with Roehl Transport or upon your transfer to a position for which the Lytx DriveCam is not utilized.
In any event, your Biometric Data will be deleted within three years of your last interaction with Roehl Transport. Redacted video footage, in which personally identifiable information has been blurred or otherwise removed, may be retained indefinitely. Any retained footage will not be retained if it includes biometric data.