Tommy Associates Pty Ltd
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Biometric Statement

Last updated date: 13th January 2021
This Statement relates to the collection and processing of data using finger scan, vein scan, and facial recognition technology (“biometric timekeeping devices”) such as those available in Tommy Kiosk Mode that maybe shared with Tommy by its customers, that maybe considered biometric data pursuant to certain states’ laws. For more information on Tommy’s privacy practices please read our Privacy Policy.
California Residents: Tommy processes your information as a service provider on behalf of Tommy customers (Employers / Team Admins). You may have rights regarding you information under California law. For more information on your rights please contact your Employer / Team Admin.


Tommy’s use of the term “biometric data” within this Statement does not reference any specific legal definition of that term. Tommy’s use of the term biometric data refers to the data collected by biometric timekeeping devices integrated with or supplied by Tommy. It is the responsibility of Tommy’s customers to determine if applicable data protection and biometric privacy laws apply to the customer’s use of biometric timekeeping devices.

How We Process Biometric Data

Tommy processes the biometric data of its customers’ employees at the direction of its customers through the use of a clock as part of a timekeeping system. The method by which Tommy processes biometric data depends on the type of clock a customer is using:
  • Finger Scan Clocks use multiple wavelengths of light to identify certain unique points on a user’s finger. The clock then creates a code based on these unique data points associated with the user.
  • Vein Scan Clocks use multiple wavelengths of light to identify certain unique patterns in the users’ finger vein system. The clock then creates a unique code based on the unique vein patterns on each finger.
  • Face Verification Clocks take a photograph of the user’s face, for purposes of visual verification of identity, the device then plots key aspects of the face using the photograph to generate a unique code associated with the user.
For each type of clock, the data collected is converted into an alpha-numeric “Template Text String” using an algorithm. Each time an individual uses the clock, it creates a temporary Template Text String which is compared to the user’s original Template Text String. The original Template Text String is stored on the clock and it is also sent to Tommy and stored in the application database. Customer’s may also choose to send photographs to Tommy through Face Verification Clocks. Each temporary Template Text String is stored only momentarily on the clock.


If consent is required to collect, store and or use the data processed by Tommy biometric timekeeping devices under any applicable laws, Tommy relies on its customers to obtain such consent or determine another lawful basis for processing biometric data. Tommy may also obtain separate written consent for the collection, storage and/or use of this information.

How We Use Biometric Data

Tommy processes biometric data only on behalf of and at the direction of its customers. Tommy’s customers may choose to use clocks to track time and attendance of their employees with or without these features.

Retention and Disposal

Biometric data is securely stored on the clock and in the Tommy application database. A user’s biometric data is deleted from the clock when the user’s status is changed to terminated or when a badge is no longer valid. A user’s biometric data is retained in the application database until 90 days after the customer changes the user’s status to terminated or a badge is no longer valid. Biometric data may also be stored in digital archives. Archived biometric data will be stored by Tommy no longer than 3 years after the date the biometric data is deleted from the application database.

How We Share Biometric Data

Tommy does not trade, sell, lease or otherwise profit from biometric data. Tommy does not authorise its vendors or customers to: use biometric data in a manner inconsistent with this Statement or Tommy’s Privacy Policy; or disclose, lease, trade, sell or otherwise profit from this data.
Biometric data may be accessed by Tommy, its subsidiaries and third-party consultants to implement and manage the services of its customers. Tommy affiliates and contractors may have access to biometric data to perform maintenance on biometric systems. Some parties with which Tommy shares biometric data may be outside of the jurisdiction in which the biometric data is collected. Where necessary, Tommy enters into appropriate lawful data transfer agreements to process biometric data outside of the jurisdiction in which it was collected.
Tommy will not share biometric data with any other third party unless:
  • The customer’s employee or the employee’s authorised representative provides written consent to share;
  • Disclosure is permitted or required by applicable law or is in response to subpoenas, court orders, or other legal processes.