Biometrica | Maryland Online Data Privacy Act (MODPA) Compliance Statement

Version: March 2025

Applicability

This statement describes Biometrica Systems, Inc.’s compliance with the Maryland Online Data Privacy Act (MODPA), effective October 1, 2025.

The MODPA exempts:

  • State and local government entities, including law enforcement agencies and their contractors.
  • Information available through lawfully maintained public records.
  • Data subject to:
    • Fair Credit Reporting Act (FCRA) — Biometrica’s eMotive solution is FCRA-compliant.
    • Health Insurance Portability and Accountability Act (HIPAA)
    • Family Educational Rights and Privacy Act (FERPA)
    • Gramm-Leach-Bliley Act (GLBA)

Because Biometrica processes law enforcement-sourced public records and operates exclusively in public safety and investigatory contexts, most MODPA provisions do not directly apply.

About Biometrica

Biometrica is a public safety technology company focused on protecting people without mass surveillance or biometric data, including and not limited to biometric templates and biometric identifiers’ access, transmission, retention, or storage.
We therefore have no biometric gallery.

Our systems include:

  • UMbRA — A 100% law enforcement-sourced database containing charge/booking data, criminal records, warrants, sex offender data, probation/parole status, and non-searchable missing persons records used solely for public safety and investigative matching. Direct UMbRA access is only available to credentialed law enforcement and quasi-law enforcement personnel.
  • RTIS & RVIS — Real-time Threat and Victim Identification Systems (RTIS & RVIS) designed to identify and locate law enforcement-verified threats or victims, or persons trespassed from a facility in real-time without retaining video, audio, or biometric data.
  • QAPLA — Face verification and similarity scoring tool available to credentialed law enforcement or approved users.
  • eMotive — Continuous, FCRA-compliant criminal background check solution requiring explicit employee consent.

Facial Recognition Technology — Privacy by Design

Biometrica is not a facial recognition company.

  • All biometric comparisons are conducted by an independent, third-party, NIST-evaluated and approved provider operating within a secure and strictly isolated black box environment.
  • Biometrica does not access, transmit, store, or retain:
    • Faceprints
    • Biometric identifiers
    • Other biometric templates (including but not limited to faceprints)
    • Associated metadata from biometric comparisons
  • We have no biometric gallery.

Biometrica only receives numerical match IDs for human verification.

Biometrica staff do not:

  • Access search queries within UMbRA
  • Access match queries performed via QAPLA
  • Access employee background monitoring records via eMotive

Only Biometrica’s Rapid Action Center (RAC) can see and send out RTIS/RVIS alerts, and that, only after verification by a human trained in facial identification, has confirmed an algorithmic match and validated it for relevance.

Use of Location Data Under MODPA

RTIS and RVIS may incorporate general location information strictly for:

  • Public safety
  • Criminal investigations
  • Missing persons recovery

Location data is:

  • Used solely for investigatory and security purposes.
  • Not used for tracking, profiling, or targeted advertising.

Compliance with the Maryland Online Data Privacy Act (MODPA)

Biometrica:

  • Does not sell personal data.
  • Does not engage in targeted advertising or commercial profiling.
  • Processes data solely for lawful, legitimate public safety purposes.
  • Applies privacy-by-design and data minimization practices throughout.

Data Subject Rights Under MODPA

Maryland residents may:

  • Access, correct, delete, or opt-out of processing of personal data as defined under MODPA.

However:

  • UMbRA’s records are publicly available government records and are strictly accessible only to credentialed law enforcement personnel.
  • Biometrica cannot alter, correct, or delete law enforcement-provided data.

Such requests must be directed to the originating law enforcement agency.

Data Minimization and Privacy Safeguards

Biometrica enforces:

  • Data minimization: Only necessary data is collected and processed.
  • Purpose limitation: Processing is restricted solely to public safety and missing persons objectives.
  • No mass surveillance: No video footage or indiscriminate collection.
  • Relevance-based alerts: Only alerts relevant to an organization’s lawful mission and legally permissible use are generated.
  • Human-in-the-loop: Every actionable alert undergoes trained human verification.
  • Immutable audit trails: All actions are logged for auditing and compliance.

Contact

Questions may be directed to:
privacy@biometrica.com

Version Control

Last Updated: March 2025
Next Scheduled Review: March 2026 or earlier if required.

Version Control:
This policy is part of Biometrica’s state privacy and biometric compliance documentation suite.
For full version history and review cycles, refer to the Biometrica Version Control Note [link TBD – do we need this?].

Version Control Notes:

  • Each policy reflects Biometrica’s operations as of March 2025.
  • Biometrica’s privacy documentation will be reviewed at least annually, and whenever:
    • New legislation is enacted or amended.
    • Relevant case law, regulatory guidance, or enforcement activity indicates the need for change.
    • Biometrica introduces or materially modifies products or services that affect data handling.
  • Previous versions will be archived and available internally for audit and compliance purposes.