Touch and Face ID Policy

Introduction

During your work for ACCO Brands, you may receive company-owned electronic devices such as smart phones, laptops or peripheral devices (collectively, “electronic devices”) which offer you the opportunity to use Touch or Face ID technology to unlock them or log in.  Touch ID is a fingerprint scan authentication system, and Face ID is a facial recognition system.  It is entirely your decision whether to use Touch or Face ID technology.  If you chose to use this optional technology, ACCO Brands has adopted the practices set forth in this Policy to explain how ACCO Brands may collect, store, use and destroy your fingerprint or face scans.  This Policy supplements any other communications and policies that relate to this subject, including applicable ACCO Brands HR Privacy Notices.

Collection, Storage, and Use Of Your Encrypted Scan

The first time you use Touch or Face ID, it scans your fingerprint and/or face to obtain an encrypted mathematical algorithm (“Encrypted Scan”), which is used to confirm your identity to unlock and/or log in to your work electronic devices.  Each subsequent scan is compared to the Encrypted Scan created by your initial scan.  Your Encrypted Scan is solely stored locally on your work smart phone, laptop or peripheral device. 

Rentention and Destruction of Your Encrypted Scan

Your Encrypted Scan will be used to unlock and/or log in to your work electronic devices during your employment and will be permanently destroyed by IT within 60 days after you return your work electronic devices to ACCO Brands.  ACCO Brands will use a reasonable standard of care in using, storing, transmitting and protecting your Encrypted Scan from unauthorized disclosure, as it does with other confidential and sensitive information. 

Prohibition on Unauthorized Disclosure

ACCO Brands will not sell, lease, trade or otherwise profit from your Encrypted Scan.  ACCO Brands will not disclose, redisclose or otherwise disseminate your Encrypted Scan unless required by law, court order, warrant or subpoena, the disclosure completes a financial transaction requested and authorized by you or your legally authorized representative, or you otherwise consent to the disclosure or redisclosure.  If ACCO Brands uses outside technical support to maintain, repair or upgrade your electronic devices or the software on your work electronic devices, you hereby consent to such access.

Updated Date: 2022.11.01