Biometric Data Policy
1. Policy
1.1. Otsuka ICU Medical LLC (collectively, “Otsuka” or the “Company”) recognizes the need to maintain the confidentiality of Biometric Data, as defined below, in accordance with applicable state, federal and local regulations and other data protection laws. This Biometric Data Policy (the “Policy”) defines Otsuka’s policy for collection, use, safeguarding, storage, and destruction of Biometric Data collected by Otsuka.
2. Scope
2.1. This Policy is applicable to all Otsuka Personnel. This Policy does not apply to Otsuka’s processes to address privacy risk management across the Company (i.e., confidential and secure handling of personal data). Please see Otsuka’s Global Privacy Policy for more information.
3. Definitions
3.1. For purposes of this Policy, the following terms have the following meanings:
3.1.1. “Biometric Data” means personal data resulting from specific technical processing relating to the physical, physiological or behavioral characteristics of a natural person, which allow or confirm the unique identification of that natural person (e.g., fingerprint scan).
3.1.2. “Biometric Identification System” or “System” means computer and/or terminal-based devices that scan Otsuka Personnel fingertips for purposes of identification. The System uses unique data points scanned at the terminal on Otsuka Personnel fingertips and creates a unique mathematical representation used to verify the identity of Otsuka Personnel; for example, when the Otsuka Personnel arrives or departs from the workplace.
3.1.3. “Otsuka Personnel” includes Otsuka officers, directors, and full-time, part-time, temporary and contract employees of Otsuka.
4. Otsuka’s Processing of Biometric Data
4.1. Otsuka collects, stores, and uses Biometric Data for the purpose of identification, training and accurate timekeeping and will not be used for any other business purpose.
4.2. Pursuant to the terms in this Policy (and in particular Section 7 below), it may be required for Otsuka to collect Biometric Data centrally, in the United States, and stored locally or via third party cloud provider.
5. Consent
5.1. In order to use the System in connection with the Otsuka Personnel’s employment, such Otsuka Personnel shall be required to sign (electronically or otherwise) a consent authorizing Otsuka to collect, store on a continual basis throughout employment and capture such Otsuka Personnel’s Biometric Data as described in this Policy.
6. Disclosure
6.1. Otsuka will not sell, lease, trade, or otherwise profit from Otsuka Personnel’s Biometric Data. Otsuka will not disclose or disseminate Otsuka Personnel’s Biometric Data unless authorized to do so by Otsuka Personnel or required to do so by state, federal and local law (and shall comply with such regulations to the extent disclosing such Biometric Data).
7. Data Storage, Retention and Deletion
7.1. Otsuka will store and protect Biometric Data using a reasonable standard of care, and in a manner that is the same as the manner in which Otsuka treats other confidential and sensitive information. Otsuka shall retain Otsuka Personnel Biometric Data only until the initial purpose for collecting or obtaining such Biometric Data has been satisfied, such as termination of the Otsuka Personnel’s employment with the Company. At that time, the Company will take the necessary steps to permanently delete Otsuka Personnel’s Biometric Data from Otsuka’s systems.
8. Auditing and Monitoring
8.1. This Policy, together with the supporting documents and records required by it, is subject to periodic auditing and monitoring.
9. Reporting and Questions
9.1. Otsuka Personnel may report any concerns through an anonymous and confidential hotline at 1-844-330-0007. Anonymous and confidential reports can also be made by email to reports@lighthouse-services.com (must include Company name in the report), through confidential web submission at https://www.lighthouse-services.com/icumed, or via the Governance Reporting section in our corporate governance website at https://ir.icumed.com/corporate-governance. Otsuka Personnel may also make confidential reports to his/her supervisor, the Company HR department, or the ICU Medical Compliance Officer.
10. Exceptions
10.1. Any exceptions to the requirements of this Policy must be approved by the Otsuka Executive Team.