The New York City Biometric Identifier Information Law ("§22-12") aims to regulate the "collection, use, and retention of biometric identifier information”. If your organization operates in New York City, you need to comply with §22-12. You can read the full text of §22-12 in the New York City Administrative Code.
Noah Facial Recognition Pty Ltd ("NoahFace") is committed to privacy and provides you with extensive capabilities in the NoahFace App and Dashboard (collectively the "NoahFace Service") to help you comply with §22-12. However, it is important to note that if your organization uses the NoahFace Service you cannot rely on the capabilities of the NoahFace Service alone. You must ensure you configure and use the NoahFace Service appropriately to comply with §22-12 and that you comply with the non-system requirements of §22-12. For example, depending on your usage of the NoahFace Service, you may need to display physical disclosure signage. Given the importance of privacy, you should obtain your own professional legal advice to ensure you are fully compliant.
The sections below detail the requirements of §22-12 and explain how NoahFace provides you with capabilities in the NoahFace Service to help you comply with each of them.
§22-12 requires that: "Any commercial establishment that collects, retains, converts, stores or shares biometric identifier information of customers must disclose such collection, retention, conversion, storage or sharing, as applicable, by placing a clear and conspicuous sign near all of the commercial establishment’s customer entrances notifying customers in plain, simple language, in a form and manner prescribed by the commissioner of consumer and worker protection by rule, that customers’ biometric identifier information is being collected, retained, converted, stored or shared, as applicable"
Most organizations use the NoahFace Service to identify employees (eg: to record their Time and Attendance) rather than customers, and as such this requirement does not apply. However, if you do use the NoahFace Service to identify customers (eg: for Visitor Registration), you must display physical disclosure signage as required.
§22-12 requires that: "It shall be unlawful to sell, lease, trade, share in exchange for anything of value or otherwise profit from the transaction of biometric identifier information."
NoahFace does NOT sell, lease, trade, share, or otherwise profit from biometric identifier information.
