This is [COMPANY]'s ("Human Pass") public policy on biometric data, including its retention schedule and guidelines for destroying it, as required by the Illinois Biometric Information Privacy Act (BIPA), and in line with Texas (CUBI) and Washington (RCW 19.375) law, the Washington My Health My Data Act, and the GDPR.
What biometric data is involved
When you verify your ID with a document scan, our identity-verification provider (Didit) takes a short selfie video and compares your face with the photo on your ID, and checks that you're a real person, present at the time ("liveness"). This uses biometric identifiers and biometric information: a scan of your face's geometry, derived from the video and the ID's photo.
Verifying with a digital licence from your phone's wallet involves no face check by us: your phone unlocks the wallet with your own fingerprint, face or passcode, on your device, and nobody receives that.
Why it's collected
Only to confirm that you are the person shown on the ID you're verifying, and that you're a real person present at the time, so that one person can only have one Human Pass. It is never used for anything else: not to identify you in other contexts, not for marketing, and not to build a face database.
Who collects it, and who receives it
- Didit collects and processes it on our behalf, as our service provider, under a contract that limits its use to this check. Didit's own notice is linked on the screen before the check.
- Human Pass never receives, stores or has access to your biometric data, the selfie video or the images of your ID. We receive only the result: whether the check passed.
- Nobody else receives it. We never sell, lease, trade or otherwise profit from biometric data, and we don't disclose it except to Didit as described, or where the law requires it.
- We've asked Didit to keep no face index linking verifications, and to keep no biometric templates.
Consent
Before every face check, a separate screen tells you what will be collected, why, by whom, and for how long, and asks for your written agreement (a checkbox and "Agree and continue"). Nothing is collected unless you agree. You can go back instead and, where it's offered, use a digital licence from your phone's wallet, which needs no face check. We keep a record of your agreement (the notice's version and a fingerprint of its wording, the provider, your language and the time; never any biometric data) as proof.
Retention schedule and destruction
| What | Destroyed |
|---|---|
| The selfie video, images of your ID, and any face geometry derived from them, held by Didit | As soon as the check is finished: Human Pass asks Didit to delete the verification session right after receiving the result, whatever the outcome. Backstop: Didit's retention for our account is set to its minimum, 30 days. |
| Any biometric data at Human Pass | None is ever received or kept. |
| Records of your consent (no biometric data) | Kept as proof of consent for [PERIOD SET WITH COUNSEL]. |
In every case, biometric data is permanently destroyed when the purpose for collecting it (the check) has been satisfied, and never later than 3 years after your last interaction with Human Pass, whichever comes first. Destruction is by deletion from the provider's systems, under its contract with us; we check each deletion request succeeds, and any that fails is logged and retried.
Security
Biometric data is protected by Didit with at least the care it uses for other confidential data, and in transit with encryption. Human Pass's systems never receive it.
Questions
[PRIVACY EMAIL] · [COMPANY], [ADDRESS]