Chief Compliance and Ethics Officer Health Care

Biometric Data Consent for Employees

  • 1.  Biometric Data Consent for Employees

    Posted 06-20-2019 01:49 PM
    Good morning,

    I'm curious to know if others are documenting consent prior to collecting biometric data on employees.  Examples might be fingerprints used to clock in, access a safe, etc. or retinal scans used for accessing certain areas of a building.

    My organization is not located in a state which requires consent, but from a risk management perspective it seems like it's not a bad idea.

    What are others doing?  Thoughts?

    Emily Roberts
    Compliance/Privacy Manager
    Morrow County Health District

    The opinions expressed are my own and are not intended to represent the positions, strategies or opinions of my employer.
    2020 HCCA Compliance Institute

  • 2.  RE: Biometric Data Consent for Employees

    Posted 06-21-2019 06:28 AM
    Not something I deal with but I do manage employee privacy in addition to patients. Employees are VERY concerned about their privacy as are patients. I would think it wise to research HR laws in this arena and adopt that standard including notice, consent and assurances that the info will not be sold etc.

    Brenda Manning J.D., C.H.C., C.H.P.C.
    Compliance Director, Privacy
    Carilion Administrative Services Building, Ste. 1201
    213 S. Jefferson Street
    Roanoke, VA 24011
    (540) 224-5757
    Fax: (540) 510-224-5787
    Integrity Help Line Compliance: (844) 732-6232

    Our Mission: Improve the health of the communities we serve.

    The views expressed herein are my own and do not represent those of my employer. They are not meant to constitute legal advice or create an attorney-client relationship.

    2020 HCCA Compliance Institute

  • 3.  RE: Biometric Data Consent for Employees

    Posted 06-21-2019 06:59 AM
    This is a huge area of my view...because quite frankly...people often do no understand the basic ideas on the use of hand scanners or other devices to capture biometric data for identification purposes to be used for time clock checking in and such.

    For some reason, maybe too many spy movies...people somehow think that some type of "copy"...often the idea of an image of a photograph or some type of similar copy of their fingerprints... often is triggered when you talk about the use of this technology which I am guessing as you may have done some homework on just not the case.

    I'd also consider some basic education (good is not very technical and people don't have to start thinking they need to be some type of techie to understand it) and this should go a LONG way in helping alleviate anxiety.

    Feel free to connect offlist...LOTS experience in this area and I do know firsthand this can go very smoothly.

    ► Week 2 of the 66ers...Ramp it Up! ◄
    --------Frank Ruelas---------

    2020 HCCA Compliance Institute