Biometrica Systems — Data Retention & Protection Policy

Last Updated: March 30, 2025

  1. Purpose

Biometrica Systems is committed to safeguarding data by applying the principles of data minimization, privacy by design, and lawful public safety use. This policy outlines how we collect, retain, protect, and, where applicable, delete data processed through Biometrica’s platforms, products, and services globally.

This policy is designed to comply with:

  • U.S. Federal and State privacy and biometric laws (including but not limited to BIPA, CPRA, VCDPA, and others)
  • GDPR (EU and UK)
  • Canada’s PIPEDA and Quebec Law 25
  • Australia and New Zealand Privacy Acts
  • The European Union Artificial Intelligence Act (AI Act)
  • FCRA (U.S. Fair Credit Reporting Act) for applicable products
  1. Privacy and Security Principles

Biometrica adheres to:

  • Data Minimization: We collect only the data needed for clearly defined lawful purposes.
  • Privacy by Design: Privacy protections are embedded into every product and workflow.
  • Relevance-Based Alerts: No alerts are triggered unless legally relevant.
  • Human-in-the-Loop: All alerts are subject to human verification.
  • Immutable Audit Trails: All access and actions are logged and preserved.
  1. Systems Covered by This Policy

3.1 UMbRA

  • A multi-jurisdictional database containing only 100% law enforcement-sourced records, including:
    • Booking data (including non-conviction data)
    • Criminal records
    • Arrest records
    • Warrants
    • Probation/parole data
    • Sex offender registries
    • Non-searchable missing persons data (AMBER, Silver, etc.)
  • Juvenile data is excluded unless the juvenile:
    • Is charged as an adult
    • Is a missing or endangered child
  • Access is restricted to credentialed law enforcement or quasi-law enforcement personnel.
  • Search activities within UMbRA are private to the agency and are never accessible to Biometrica staff.
  • All events create an immutable audit log.

3.2 RTIS & RVIS

  • Perform real-time threat and victim identification without:
    • Video capture or storage
    • Biometric template generation (no faceprints)
    • Biometric identifier retention
  • Images are deleted immediately if no match is found.
  • Images triggering alerts are retained only as part of a secure chain of custody, stripped of location metadata.
  • All biometric comparisons are performed externally by a third-party, NIST-evaluated, FedRAMP-authorized provider operating in a black box environment.
  • No biometric data is ever:
    • Generated
    • Accessed
    • Stored
    • Transmitted by Biometrica

3.3 QAPLA

  • A face verification and similarity tool.
  • Generates no biometric templates, faceprints, or biometric galleries.
  • Used exclusively by credentialed law enforcement or authorized partners.
  • All matching is performed externally via the black box.
  • Biometrica does not access search results or verification records.

3.4 eMotive

  • Provides a continuous, FCRA-compliant criminal background check.
  • Requires explicit consent from employees or monitored individuals.
  • Only checks for criminal activity; does not review:
    • Social media
    • Credit scores
    • Property records
    • Educational history
    • Drug testing
    • Non-criminal infractions
  • Data processed complies with FCRA and applicable labor law requirements.
  1. Data Deletion and Minimization
  • All unmatched images are automatically deleted.
  • Matched images generating valid alerts are retained only for:
    • Digital chain of custody
    • Legal or audit requirements
  • All metadata (including GPS coordinates) is stripped prior to long-term retention.
  • No facial templates, biometric identifiers, or associated biometric data are stored.
  • Data is retained only for the minimum period necessary under applicable law.
  • Biometrica does not retain biometric data or AI-generated pointer data. Any AI-generated match data is used solely for real-time alerting, reviewed by trained personnel, and, if not acted upon, is purged in accordance with applicable retention guidelines.
  1. Security Safeguards
  • AES-level encryption of all data in transit and at rest.
  • Role-based access control with strict compartmentalization.
  • Immutable audit logging of all system access and data usage.
  • Vulnerability scanning and secure development practices.
  • Data flow architecture built on JMS one-way data feeds:
    • Data flows into Biometrica systems but cannot be replicated back out.
    • Reduces risk of compromise even if a partner system is breached.
  • Alignment and compliance with CJIS recommended practices, although not formally CJIS certified.
  1. Cross-Border Data Transfers
  • Conducted using:
    • Standard Contractual Clauses (SCCs)
    • Adequacy decisions
    • Other jurisdiction-appropriate safeguards
  • Biometrica maintains servers and operations in the U.S. and other permitted jurisdictions.
  1. Algorithm Agnosticism
  • Biometrica licenses facial recognition algorithms from independent, third-party providers that are:
    • NIST-tested
    • FedRAMP-authorized
  • Biometrica does not develop or control these algorithms.
  • All matching occurs in a third-party black box separate from Biometrica’s internal environment.
  1. Chain of Custody & Audit
  • All alert events, system access, and human verification activities are logged and cannot be altered.
  • The integrity of this immutable audit trail is a critical part of both internal and external compliance.
  1. Request for Additional Details

For those seeking more technical or compliance details, Biometrica makes available a Security and Compliance FAQ.
Please contact:
privacy@biometrica.com
to request the document.

  1. Updates

This policy will be reviewed and updated as necessary.
The “Last Updated” date reflects the most recent version.