Biometric Processing Policy
Purpose
Safelite Group, Inc., and its affiliates (collectively “Safelite”) have adopted this Biometric Processing Policy (this “Policy”) to govern the collection of Biometric Information (defined below) by video recording devices (the “Device”) in all Safelite-owned or leased vehicles.
To the extent applicable to current or former Associates, this Policy is expressly incorporated by reference herein to the Safelite Employee Privacy Notice available at: https://safelitepeopleguide.com/policy/employee-privacy-notice/. In the event of a conflict between this Policy and the Safelite Employee Privacy Notice, the terms of this Policy will supersede.
To the extent applicable to Job Applicants, this Policy is expressly incorporated by reference herein to the Job Applicant Privacy Notice available at: https://www.safelite.com/careers/safelite-applicant-privacy-policy. In the event of a conflict between this Policy and the Job Applicant Privacy Notice, the terms of this Policy will supersede.
Scope
As part of ongoing efforts to improve safety and security, Safelite and third-party service providers contracted by Safelite (“Suppliers”) may collect and use Biometric Information from prospective job applicants (“Applicant”) and current Safelite associates (“Associate”) in certain instances.
“Biometric Information” means any information used to identify an individual based on an individual’s retina or iris scan, fingerprint, voiceprint, scan of hand or face geometry, the status of your facial features (e.g., the distance between your eyes, nose, and ears, and/or eyes open or closed, direction eyes are looking), any unique biological patterns or characteristics used to identify an individual, or data generated by automatic measurements of such patterns or characteristics.
This Policy applies to any Applicant (for example, any Applicant who is applying for a position in the Safelite Contact Center) or Associate (for example, any Associate that has the potential to operate a Safelite vehicle that has a Device (defined below) installed or be a passenger in a Safelite vehicle that has a Device installed) who provides Biometric Information to Safelite for the purposes described herein.
How Biometric Information is Collected
Applicant Identity Verification
Safelite and Suppliers may collect, store, and use identifying information an Applicant submits, such as a government-issued identification card and a current photo, to generate Biometric Information, including a facial map, to conduct a face match for security purposes to verify the Applicant’s identity and ensure the Applicant is who they represent to be and is not a robot. Safelite and its Suppliers may retain, use, and disclose government-issued identification and a current photo to the extent permitted by law and the Job Applicant Privacy Notice.
Video Recording Device in Safelite Vehicles
Safelite and Suppliers will or have installed video recording devices (the “Device”) in all Safelite-owned or leased vehicle, and may use software in connection with the Device to create a physical profile of you based on Biometric Information the Device captures, such facial images, measurements, proportions and/or the status of your facial features (e.g., the distance between your eyes, nose, and ears, and/or eyes open or closed, direction eyes are looking), including related metadata and derived data. Safelite and its Suppliers may use Biometric Information collected in correlation with the Device to identify you and to analyze your behavior (e.g., looking away from the road, looking at a phone, eating while driving, drowsiness/fatigue) for safety purposes.
The Device is equipped to record video both inside and outside the vehicle and recording is designed to activate upon the detection of specific safety incidents, including but not limited to collisions, hard braking, driver inattention, and/or unsafe driver behavior. However, the Device may record at any time, regardless of whether a safety incident has occurred. You may or may not receive notifications when recording is initiated. Therefore, you should assume (1) the Device is recording at all times, and (2) Safelite and its Suppliers may access any recording, irrespective of an associated safety incident. Safelite and its Suppliers may retain, use, and disclose video recordings to the extent permitted by law and the Safelite Employee Privacy Notice.
Audio Recording and Privacy Expectations. The Device will not record audio. Nonetheless, you have no expectation of privacy while in or around a Safelite-owned vehicle. You should refrain from engaging in private actions or conversations in these areas.
Additional Data Collection. The Device may also collect various types of trip-related information. This includes, but is not limited to, vehicle speed, GPS coordinates, precise geolocation, acceleration, braking, collision events, mileage, proximity to other vehicles, road signs, traffic signals, road conditions, traffic patterns, parking spaces, and license plate numbers of surrounding vehicles (collectively, “Additional Data”). Safelite and its Suppliers may retain, use, and disclose Additional Data to the extent permitted by law and the Safelite Employee Privacy Notice.
Biometric Information Retention Schedule.
Safelite and its Suppliers may retain, use, and disclose Biometric Information collected as described in the Video Recording Device in Safelite Vehicles section for one (1) year after the date of recording. Safelite and its Suppliers may retain, use, and disclose Biometric Information collected as described in the Applicant Identity Verification for seven (7) days after ID verification. Thereafter, the Biometric Information is destroyed by Safelite and/or Supplier. The aforementioned retention period may be suspended without notice if the Biometric Information becomes relevant to actual or potential legal claims or disciplinary proceedings, or as otherwise required in compliance with applicable laws.
Biometric Information Disclosures
Safelite may disclose Biometric Information to the extent permitted by law and the Safelite Employee Privacy Notice. Safelite will not further disclose or re-disclose Biometric Information unless:
- You consent to the disclosure.
- The disclosure is required by applicable law or regulation.
- The disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.
- Safelite does not sell, lease, trade, or otherwise profit from Biometric Information.
Biometric Information Security
Safelite and its Suppliers will use a reasonable standard of care to store, transmit, and protect Biometric Information. In the event of a data security incident involving Biometric Information, relevant Safelite teams will promptly assess the nature and scope of the incident to determine the extent of exposure and potential impact. Immediate steps will be taken to mitigate any potential harm, such as securing affected systems and preventing further unauthorized access. Safelite and/or its Suppliers will notify affected individuals and other relevant third parties, if required, in compliance with applicable laws.
Policy Updates
Safelite reserves the right to make changes to this Policy at any time. If we determine that a change to this Policy will result in using your Biometric Information acquired before the change in a materially new way, we will provide you notice and meet other applicable legal requirements before using your Biometric Information in the new way.
If you have any questions about this Privacy Notice, please contact us at:
Email: peopledirect@safelite.com
Mailing Address:
Safelite Group, Inc.
Attn. People Direct
7400 Safelite Way
Columbus, Ohio 43235