ɫƵ Biometric Data Policy
Effective date: 10/28/2024
The ɫƵ, Inc. (“University,” “us,” or “we”) has instituted the following Biometric Data Policy (this “policy”) to describe our practices with respect to the collection, disclosure, safeguarding, retention, use, and destruction of Biometric Data, as defined below. Additional information on the University’s privacy practices can be found in our Privacy policy.
1. Biometric Data Defined
For purposes of this policy, “Biometric Data” means data generated by the technological processing or analysis of an individual's biological or physical characteristics (often referred to as “biometric identifiers”) that can be processed for the purpose of uniquely identifying an individual. Common examples include fingerprints, voiceprints, scans of a hand, facial geometry recognition, and iris or retina recognition. As used in this policy, Biometric Data includes “biometric data,” "biometric identifiers," or "biometric information" as defined under applicable law.
2. Biometric Data We Collect
We may collect the following Biometric Data:
Facial Biometric Data: We may require you to upload an image of your government-issued or other identification document(s) as well as your photographic image (or "selfie") using your mobile or other personal device. The selfie will be used to confirm you are a real person and are the person who appears on the government-issued identification document. During this process, we may derive your facial geometry, or “faceprint,” from the images you provide.
3. Purpose for Collection of Biometric Data
Biometric Data collected and/or derived by the University is solely for the purpose of verifying your identity to prevent fraudulent activity. We will not sell, rent, or trade your Biometric Data or otherwise leverage or exploit your Biometric Data for profit, and we will not process your Biometric Data for the purpose of inferring characteristics about you.
4. Disclosure of Your Biometric Data
We will not disclose or disseminate any Biometric Data to anyone other than the Service Provider(s) of the University’s biometric software that processes the Biometric Data solely for the purposes of assisting us in identity verification and fraud detection. Our Service Provider(s) will only collect, process, and store Biometric Data in accordance with this policy and will not be permitted to redisclose the Biometric Data to any third party.
5. Retention of Biometric Data and Data Security
The University or its Service Provider(s) will retain facial geometry scans and the resulting Biometric Data for only the period reasonably necessary to verify your identity, and, in any case, for no longer than twenty-four (24) hours. Biometric Data is collected for the operation, performance, and support of identity verification and will thereafter be permanently deleted. The University will store, transmit, and protect any Biometric Data from disclosure using a reasonable standard of care and in the same manner the University stores, transmits, and protects other confidential and sensitive information.
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As part of the identity verification process and before you provide images of your government-issued identification document and selfie, you will be asked to agree to this policy and voluntarily consent to our collection and use of your Biometric Data to verify your identity. As stated in this policy, we do not retain your Biometric Data after the identify verification has been completed. Therefore, you will not be able to revoke consent once images of your government-issued identification and your selfie have been submitted.
You may refuse to consent to the collection of your Biometric Data. Please note that if you refuse to consent to the collection and processing of your Biometric Data, we may not be able to verify you at the required level of assurance to process your admissions application online.
The University provides an alternate pathway for individuals to verify their identity. If you do not consent to the collection and use of your Biometric Data in the manner described above, you have the option to speak with an authorized representative by calling 844-417-0931.
8. Contact Information
Should you have any questions about this policy, please contact us at Office.ComplianceUOPX@phoenix.edu or by mail:
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Ethics, Compliance, and Data Privacy
4035 S. Riverpoint Parkway
Phoenix, AZ 85040
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