Biometrica | Virginia Consumer Data Protection Act (VCDPA) Compliance Statement

Version: March 2025

Applicability

This disclosure outlines Biometrica Systems, Inc.’s compliance with the Virginia Consumer Data Protection Act (VCDPA) applicable to the collection and processing of personal data relating to Virginia residents.

Biometrica notes that under the VCDPA, “personal data” does not include publicly available information, including lawfully made available records from government entities.
Biometrica’s core dataset, UMbRA, is exclusively composed of lawfully sourced government and law enforcement records and is therefore excluded from the definition of personal data under the VCDPA.

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 or 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 receives only numerical match IDs which are subject to human review.

Biometrica staff never have access to:

  • Search queries within UMbRA
  • Match queries via QAPLA
  • Continuous monitoring results 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 VCDPA

RTIS and RVIS may associate alerts with general location information strictly for:

  • Public safety
  • Criminal investigations
  • Recovery of missing persons

This location data:

  • Is not used for consumer profiling, advertising, or commercial purposes.
  • Is permissible under the VCDPA’s exceptions for public safety, law enforcement, and investigatory uses.

Compliance with the Virginia Consumer Data Protection Act (VCDPA)

  • Biometrica complies fully with the VCDPA by:
  • Not selling personal data.
  • Not processing sensitive data without proper consent.
  • Avoiding automated profiling with legal or similarly significant effects.
  • Processing only for lawful, legitimate public safety purposes.
  • Ensuring privacy-by-design and data minimization across all operations.

Data Subject Rights Under VCDPA

Virginia residents may:

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

However, Biometrica’s law enforcement database (UMbRA) is:

  • Exempt as it comprises publicly available government records.
  • Restricted solely to credentialed and trained law enforcement users.
  • Immutable due to chain-of-custody and evidentiary integrity obligations.

For this reason:

  • Biometrica cannot grant access, correction, or deletion of records within UMbRA.
  • Any such requests must be directed to the originating law enforcement agency.

Biometrica is legally and contractually prohibited from modifying law enforcement-provided data, even in cases of apparent error.

Requests for information may be submitted via:
privacy@biometrica.com

Data Minimization and Privacy Safeguards

Biometrica enforces:

  • Data minimization: Only necessary data is collected and processed.
  • Purpose limitation: Processing is solely for 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

For questions regarding this policy:
privacy@biometrica.com

Version Control

Last Updated: March 2025
Next Scheduled Review: March 2026 or earlier if required by legal or regulatory changes.

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.