ELECTRONIC TIMEKEEPING AND ELECTRONIC SYSTEMS POLICY, DISCLOSURE AND CONSENT

To record timekeeping data in an accurate manner while protecting against erroneous timekeeping entries by unintentional mistake or without authorization, AbleHearts, together with its Affiliates, including but not limited to skilled nursing facilities and supportive living facilities, (hereinafter the “Company”) uses an electronic timekeeping system that requires employees to use fingerscan technology when entering timekeeping data. In addition, the Company uses finger and/or facial scanning technology for certain employees to securely log in to Company networks, computer systems, laptops, phones/smartphones, copiers, and applications on laptops, tablets, and smartphones (“Company Electronic Systems”).

Purpose

The specific purposes for the Company’s use of such a timekeeping system is to promote the accuracy and integrity of timekeeping data, prevent against either intentional or unintentional inaccuracies in timekeeping data, and ensure only authorized individuals can record timekeeping data on behalf of any specific employee.

The specific purposes for the Company’s use of employee’s finger and/or facial scans when accessing Company Electronic Systems is to authenticate the employee as an authorized user and ensure the security of the Company Electronic Systems and Company networks.

Collection, Storage, and Usage of Information

Upon acceptance of and as a condition of employment, all individuals employed by the Company must create a two-step User Profile within the Company’s timekeeping system, comprised of a unique Personal Identification Number (PIN) and a scan of the individual’s hand or fingers (“User Profile”). Once created, the Company’s timekeeping system stores the unique identifying information for each employee’s User Profile for the duration of the employee’s employment so that every time the employee makes a timekeeping entry by either “clocking in” or clocking out,” the timekeeping system can verify that the employee inputting information is doing so on his or her own behalf. The information in each employee’s User Profile, particularly with respect to finger scan information, is used only for timekeeping validation and integrity purposes and for no other purpose. The Company’s other databases and systems do not have access to the unique identifying information in each employee’s User Profile and that information is not shared across any Company systems or databases.

In addition, the Company at times may require employees to use finger and/or facial scanning technology to access Company Electronic Systems. Employees are required to provide a finger scan when first using certain Company Electronic Systems in order to authenticate them as an authorized user in the future. The finger and/or facial scans are combined with digital secure certificates and are securely stored within the network and only used for authentication purposes on Company Electronic Systems.

Retention and Destruction of User Profile Information

The Company’s timekeeping system retains each employee’s User Profile and the identifying information within the User Profile for as long as the employee remains employed by the Company. The Company will store, transmit, and protect biometric data using the same standard of care and security controls it provides the protected health information in its possession. Unless otherwise required by law, within 30 days of termination of employment, an individual’s User Profile, including the PIN and finger scan identifiers, are purged from the timekeeping system without the creation or maintenance of any “backup” data or information. Should any individual terminate his or her employment with the Company and later resume employment with the Company, he or she must create a new User Profile within the timekeeping system.

Additionally, upon written request by an employee, the Company will purge his or her existing User Profile from the timekeeping system and allow the employee to create a new User Profile. However, because creation of a User Profile and use of the Company’s timekeeping system are conditions of employment, no individual who must record time will be permitted to maintain employment with the Company without having an active User Profile in the timekeeping system. Accordingly, an employee who wishes to have the information in his or her User Profile purged without creating a new User Profile will be required to resign employment with the Company, and if he or she does not do so, will be deemed to have resigned employment with the Company.

Employee finger and/or facial scans used to securely access Company Electronic Systems are retained within the Company’s network for the duration of an employee’s employment with the Company using the same standard of care and security controls it provides the protected health information in its possession. Unless otherwise required by law, employee finger and/or facial scan data is destroyed within 30 days after the employee ends their employment with the Company. Additionally, upon written request by an employee, the Company will purge their existing finger and/or facial scans from Company Electronic Systems. However, because the secure access to Company Electronic Systems via finger scan technology is a condition of employment, no employee will be permitted to maintain employment with the Company without using this finger scanning technology.

Disclosure of User Profile Information

The Company’s timekeeping system is a web-based system. The Company contracts with third-party vendors, specifically SmartLinx Solutions, LLC, to provide these services. Therefore, each employee’s User Profile, including the finger scan and/or PIN number, may be securely transmitted to the third-party website each time an employee “clocks in” or “clocks out” of work to track the employee’s time.

Employee finger scans for securely accessing Company Electronic Systems are maintained entirely within the Company’s network and not disclosed to any third-parties.

The Company will not disclose unique identifying information from an employee’s User Profile to any other third party unless: (i) the employee first provides a written consent for the disclosure that includes specific direction on to whom and how the Company should make the disclosure and for what purpose; (ii) the disclosure is required by applicable federal, state or local law; or (iii) the disclosure is required in response to a validly issued and served warrant or subpoena.

Retention and Destruction of User Profile Information

If you have any questions, please contact Ms. Teresa Evans at Teresa.evans@ablehearts.org

Availability of This Policy

A copy of this policy, disclosure and consent form is publicly available online and additional copies will be made available upon written request directed to Ms. Teresa Evans at Teresa.Evans@ablehearts.org 

Consent to Policy and Release

By my signature below, I affirm that I have read this Electronic Timekeeping and Electronic Systems Policy, Disclosure and Consent form, had the opportunity to ask any questions about it, and fully understood it prior to placing my signature below. I also understand that it is a condition of employment with the Company that I create and maintain a User Profile within the Company’s timekeeping system that includes a PIN and the use of finger scan technology, and that I may be required to provide finger and/or facial scans to securely access Company computer systems, laptops, phones/smartphones, copiers, and applications on laptops, tablets, and smartphones.

I further expressly consent to the Company’s use of: (1) the information in my User Profile within the timekeeping system and (2) finger and/or facial scans for securely accessing Company Electronic Systems. I understand the Company uses this information for the purposes and within the parameters described herein, and expressly release the Company from any claims arising from such use. I additionally acknowledge my understanding that upon my written request, the Company will purge the information from my User Profile, and I may either create a new User Profile or will be deemed to have resigned my employment with the Company if I do not create a new User Profile. Similarly, I acknowledge my understanding that upon my written request, the Company will purge my finger scans from Company Electronic Systems, and I may either create new finger scans or will be deemed to have resigned my employment with the Company.