Effective January 2025: The following is a summary of Lakeshore Recycling Systems, LLC’s (“LRS”) policies regarding the retention, collection, disclosure, and destruction of Employees’ Biometric Data. This policy is available for review by the public at www.LRSrecycles.com. This release replaces and supersedes all previous policies related to Biometric Data.

1. Purpose

LRS collects, uses, and stores the Biometric Data of certain hourly employees (“Employees”) for the purpose of identifying Employees and recording their time entries through the use of biometric readers and associated payroll software. As used in this policy, “Biometric Data” refers collectively to fingerprints, scans of the finger, scans of hand geometry, or facial scans, and information based on an individual’s fingerprints, scans of the finger, scans of hand geometry, or facial scans.

LRS has installed and uses biometric readers in order to more efficiently and accurately record Employees’ time entries.

2. Collection

LRS currently uses ADP’s InTouch DX G2 Finger Scan Devices (“Finger Scanners”). Finger Scanners use an algorithm to generate a biometric template, which is derived by examining the ridges and valleys on an Employee’s finger. This information cannot be reverse engineered, nor can it be used to reproduce a fingerprint.

LRS may use ADP’s InTouch DX G2 Facial Recognition Devices (“Face Scanners”). LRS may use Face Scanners in addition to or instead of Finger Scanners to record time entries. Face Scanners take a photograph of an employee’s face and use data from it to create a template that is securely stored in the device and on LRS’s timekeeping database during the employee’s employment. 

3. Storage

LRS takes care to ensure the privacy and security of its Employees’ Biometric Data. Biometric templates generated by Finger Scanners are stored in a secure cloud-based database maintained on ADP’s servers. ADP securely accesses any Biometric Data captured and stored as a result of an Employee’s use of Finger Scanners in accordance with all applicable legal requirements. LRS does not directly access or view Biometric Data stored within the Finger Scanners. Biometric templates generated by Facial Scanners will be securely stored in the device and in the secure cloud-based database maintained on ADP’s servers. Biometric Data is not disclosed by ADP to any third-parties. Should that change, this policy will be updated accordingly, and Employees will be asked to consent in writing to such disclosure(s).

LRS protects Biometric Data to the same or to a greater extent as it protects other confidential and sensitive information, such as social security numbers.

4. Retention & Destruction

LRS or ADP (as applicable) will retain an Employee’s Biometric Data for the duration of the Employee’s employment, for only so long as the Employee consents to the retention of such Biometric Data for the purposes described in this policy, or for up to three years following the Employee’s last interaction with LRS, whichever comes first. An Employee’s Biometric Data will be permanently destroyed by LRS or ADP (as applicable) as follows: (i) promptly following LRS’s receipt of an Employee’s written revocation of consent; or (ii) promptly following an Employee’s separation from employment with LRS. An Employee’s Biometric Data also will be permanently deleted no later than three years following the Employee’s last interaction with LRS.

5. Written Authorization/Condition of Employment

Employees are provided with information regarding the purpose of LRS’s collection, storage, transmission, and use of their Biometric Data, and are asked to provide written authorization consenting to the collection, storage, and use of their Biometric Data by LRS, pursuant to the terms of this policy. While Employees are free to withhold or revoke their authorization in writing, consent to LRS’s use of Biometric Data as described in this policy is a condition of Employees’ employment, or continued employment, with LRS.

In the event LRS seeks to collect Biometric Data not outlined in this Policy, LRS will update this Policy accordingly, and Employees will be asked to consent in writing to the updated Policy.