Biometric Information Security

1. PURPOSE

1.1. This Biometric Information and Security Policy (“Policy”) defines American Cleaning & Restoration South, and its affiliates, (collectively “the Company” or “American Cleaning & Restoration South”) policy and procedures for collection, use, safeguarding, storage, retention, and destruction of biometric data collected by AMERICAN CLEANING & RESTORATION SOUTH.

1.2. The Company may use biometric identification systems for employee timekeeping at the facility located at 1345 Lakeside Drive, Romeoville, IL 60446.

2. DEFINITION OF BIOMETRIC DATA.

Biometric data means personal information stored by AMERICAN CLEANING & RESTORATION SOUTH about an individual’s physical characteristics that can be used to identify that person. Biometric data specifically includes fingerprints and/or hand scans. As technology and systems advance, biometric data may also include voiceprints, retina or iris scan, or scan of face geometry.

3. POLICY

3.1. AMERICAN CLEANING & RESTORATION SOUTH’S policy is to protect and store biometric data in accordance with applicable standards and laws including, but not limited to, the Illinois Biometric Information Privacy Act.

3.2. An individual’s biometric data will not be collected or otherwise obtained by AMERICAN CLEANING & RESTORATION SOUTH without the written consent of the individual. AMERICAN CLEANING & RESTORATION SOUTH will inform the employee of the reason his or her biometric information is being collected and the length of time the data will be stored. A sample consent statement is included in this policy.

3.3. AMERICAN CLEANING & RESTORATION SOUTH maintains control over the information and does not and will not sell, lease, trade, or otherwise profit from an individual’s biometric data. Biometric data will not be released by AMERICAN CLEANING & RESTORATION SOUTH unless (i) consent is obtained, (ii) disclosure is required by law, or (iii) required by valid legal subpoena.

3.4. Biometric data will be stored, used and protected using a reasonable standard of care for AMERICAN CLEANING & RESTORATION SOUTH’S industry and in a manner that is the same or exceeds the standards used to protect other confidential and sensitive information held by AMERICAN CLEANING & RESTORATION SOUTH. No AMERICAN CLEANING & RESTORATION SOUTH employee outside of the President, Vice President and Human Resources will have direct access to biometric data.

3.5. AMERICAN CLEANING & RESTORATION SOUTH will permanently destroy biometric data within a reasonable period of time of when the purpose for obtaining or collecting such data has been fulfilled. Generally, this means within one (1) month of an employee’s termination of employment but in no event will it be longer than three (3) years.

3.6. Prior to collecting an individual’s biometric data, AMERICAN CLEANING & RESTORATION SOUTH will obtain the written consent of the individual. Consents will be stored by human resources in employee personnel records.

3.7. This Policy replaces and supersedes all previous policies related to biometric information. AMERICAN CLEANING & RESTORATION SOUTH reserves the right to amend this Policy at any time, without notice. AMERICAN CLEANING & RESTORATION SOUTH may expand its use of biometric data in the future.

3.8. In the event AMERICAN CLEANING & RESTORATION SOUTH begins collecting biometric data for any additional purpose, AMERICAN CLEANING & RESTORATION SOUTH will update this Policy.

3.9. A copy of this document can be found available to the public www.americancleaningsouth.com or “upon request”.