Great Northern Corporation’s Biometric Data Policy and Notice

Purpose
To ensure compliance with the Illinois Biometric Information Privacy Act (“BIPA”), Great Northern Corporation (the “Company” or “GNC”) has adopted this Biometric Data Policy and Notice (this “Policy”) to govern the collection, capture, use, safeguarding, retention, and destruction of GNC’s team members’ Biometric Data, as that term is specifically defined in this Policy.
Scope
This Policy applies to all GNC team members, as well as any GNC approved third-party service provider engaged by GNC, who under this Policy and on behalf of the Company, as applicable, collects, captures, uses, processes and/or stores GNC’s team members’ Biometric Data, as that term is specifically defined in this Policy, regardless of the type of media on which that information is captured and/or stored.
Definitions
“Biometric Data” means the specific Biometric Identifier and Biometric Information defined and set forth under this Policy.
“Biometric Identifier” means a unique biological characteristic used to identify an individual. For purposes of this Policy, “Biometric Identifier” refers to a GNC team member’s voiceprint, which is a measurable, unique representation of an individual’s voice used for identification or authentication, which is captured during any virtual GNC work-related meeting conducted on any GNC digital licensed platform, including but not limited to Microsoft Teams.
“Biometric Information” means information, regardless of how it is captured, collected, processed, converted, stored, or shared, which is based on the Biometric Identifier set forth under this Policy. Biometric Data does not include information derived from items or procedures excluded under the definition of Biometric Identifiers under applicable law.
Retention Schedule
In circumstances where GNC captures and retains a team member’s Biometric Data as defined under this Policy, GNC will permanently delete the team member’s Biometric Data within one (1) year after the team member’s separation of employment with GNC for any reason, regardless of whether the separation is voluntary or involuntary.
Biometric Data Collection
To accurately attribute text in a digital transcript generated on any GNC digital licensed platform for GNC team members who attend GNC work-related virtual meetings on any GNC digital platform, including but not limited to Microsoft Teams, GNC and/or its approved third-party service provider, as applicable, may collect, capture, use, process, and/or store GNC team members’ voiceprints. Doing so assists in accurately assigning speaker attribution, voice isolation and meeting transcription.
Biometric Data Security
GNC and/or its third-party vendors shall use a reasonable standard of care, as applicable, to collect, capture, use, process, store, transmit and/or protect from disclosure any paper or electronic Biometric Data collected under this Policy.
Biometric Data Disclosures
Subject to each team member’s consent, GNC may disclose a team member’s Biometric Data, as defined under this Policy, to its approved third-party service provider for purposes of identifying individual GNC team member speakers attending virtual work-related meetings on any GNC digital licensed platform, including but not limited to Microsoft Teams, to correctly attribute text in the transcript to a specific GNC team member-attendee.
GNC prohibits any further disclosure or re-disclosure of team member Biometric Data under this Policy unless:
· The team member or the legally authorized representative of the team member consents to the disclosure;
· The disclosure is required by applicable law or regulation; or
· The disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.
GNC does not sell, lease, trade, or otherwise profit from team member Biometric Data.

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