TransAm Trucking, Inc.
Biometric Data Retention and Deletion Policy
TransAm Trucking, Inc. (“TransAm”) has instituted the following Biometric Data Retention and Deletion Policy (“Policy”):
Definitions
“Biometric Data” as used in this Policy includes both: (i) “Biometric Identifiers”, meaning a facial, retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry or other physiological traits; and (ii) “Biometric Information”, meaning any information, regardless of how it is captured, converted, stored, or shared, that is based on Biometric Identifiers, including a facial, retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry, that is used to identify an individual.
Purpose
The Policy defines TransAm’s policy and procedures for the collection, use, safeguarding, storage, retention, and destruction of Biometric Data collected by TransAm and/or its vendors in accordance with applicable law, including but not limited to, the Illinois Biometric Information Privacy Act (“BIPA”), 740 ILCS § 14/1, et seq.
TransAm requires all motor vehicles operated under its operating authority to be equipped with Motive Technologies, Inc.’s (“Motive AI”) AI Dashcam camera system and related hardware and software technology (“Dashcam”), including artificial intelligence and machine vision, to manage our fleet and improve driver safety. The Motive AI Dashcam and system utilized by TransAm currently includes a road-facing camera to capture video footage of critical events outside of the vehicle, but does not include an inward facing camera. To the extent that this video footage and data collected from Motive AI’s Dashcam and system is considered Biometric Data, Motive AI’s technology allows TransAm to use this Biometric Data to confirm that the Dashcams are not obstructed or blocked, to analyze driving and driver performance, to improve customer service, optimize efficiency, and improve safety, for legal or litigation purposes and defense, to analyze risk and to analyze driving events. Using the Motive AI Dashcam and system enhances safety by increasing the efficacy of Motive AI’s driver-based insights to help improve driver safety and efficiency, and also helps TransAm to maintain accurate logs of our operations.
The data collected from Motive AI’s Dashcam will be disclosed to and stored by Motive AI. If the data collected from Motive AI’s Dashcam and system is considered Biometric Data, then Motive AI will have access to the Biometric Data to perform the functions of its services agreement with TransAm. A copy of Motive AI’s privacy policy is available at https://gomotive.com/legal/biometric-data-collection-policy/.
Data Retention, Protection and Disclosure Policy
TransAm shall use a reasonable standard of care to store, transmit, and protect from disclosure any Biometric 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 TransAm stores, transmits, and protects from disclosure other confidential and sensitive information. Any Biometric Data collected from drivers using Motive AI’s Dashcam and system will not be disclosed to parties other than TransAm or Motive AI, except in the following circumstances: (1) after TransAm 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 TransAm, the Biometric Data may be shared with only those employees who have a need to know for a specific business purpose.
Retention and Destruction of Biometric Data
TransAm will retain any Biometric Data collected using the Motive AI Dashcam and system for a period of one (1) year, unless such data must be retained longer as evidence in connection with litigation (e.g., evidence of an accident) in accordance with applicable law, in which case it will be retained for so long as required then destroyed.