3P Security GroupPrevent · Protect · Preserve
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Biometric records review

Fingerprint records and face-match settings, traced to the paperwork the center has and the answers it still needs.

Discuss a review
Prepared for
Kestrel Loom Community Center
Property
Illinois nonprofit community center
Records reviewed
October 30, 2026
Prepared by
3P Security Group

What we looked at

We read the center's policies, handbook acknowledgment, vendor terms and access list, alongside settings screenshots supplied by the owner. The review follows the records for each device.

Device and data inventory
DeviceData it can collectState shown in recordsWho holds the data
A · Staff time clockFingerprint template linked to a staff record.Fingerprint attendance is on.Vendor cloud. The center can manage staff records; template export rights are unanswered.
B · Camera appFace-geometry templates used for matching, as described in the supplied feature sheet.Face matching is on. The setup record marks it as the default.Vendor cloud. The center's manager and a vendor support role can export match records.
C · Staff door readerFingerprint templates if enrollment is enabled.Fingerprint enrollment is off. Staff use badges.No fingerprint records shown. Badge records are held by the center.
D · Visitor kioskVisitor photos. The supplied feature sheet describes no face matching.Photo capture is on.Center-held photo records. The vendor's written confirmation of photo-only processing is on file.

The visitor photo file and its retention record are on file. The open biometric records work concerns the time clock and camera app, plus the decision to keep fingerprint enrollment off at the staff door.

Devices and paperwork

Choose a pin to read the records finding for that location. Every finding is also written out below.

Community center room planStaff office and staff entrance above a community room, lobby and reception. Pins A through D connect the devices to their records findings. Staff officeStaff entryCommunityroomLobbyReception A B C D
Room relationships only. Not to scale.
  • Paperwork in place
  • Paperwork missing
  • Feature can be turned off

Pin colors describe the records and available feature choices. The camera app still has missing paperwork. The visitor kiosk status describes its photo records.

What the law says

The Illinois Biometric Information Privacy Act, 740 ILCS 14, distinguishes photographs from scans of face geometry. Section 10 includes fingerprints and scans of hand or face geometry in "biometric identifier" and excludes photographs. We check what each feature produces.

Section 15: the law and the records we check
SectionThe law saysWhat we check
15(a)RetentionA private entity holding biometric identifiers or information must have a public written retention and permanent-destruction policy. Destruction is tied to the initial purpose being satisfied or within 3 years of the person's last interaction, whichever comes first. The entity must follow its schedule, absent a valid court warrant or subpoena.The public policy, its retention triggers and the owner's records of vendor deletion settings and completed deletions.
15(b)Before collectionBefore collecting or otherwise obtaining biometric identifiers or information, a private entity must give written notice of collection or storage, the specific purpose and length of term, and receive a written release from the person or their legally authorized representative.The notice and release wording, the version signed, and whether the release predates collection.
15(c)No sale or profitA private entity holding biometric identifiers or information may not sell, lease, trade or otherwise profit from them.Contract terms on data use, transfers and any right to reuse biometric records.
15(d)DisclosureDisclosure or redisclosure is limited to consent from the person or their legally authorized representative, completing their requested or authorized financial transaction, a requirement of State or federal law or municipal ordinance, or a valid court warrant or subpoena.Who receives records, who can export them, and the written basis recorded for each disclosure.
15(e)Care of the dataStorage, transmission and protection from disclosure must use reasonable care within the entity's industry and be at least as protective as its treatment of other confidential and sensitive information.Written safeguards, access roles and the owner's comparison with protections for its other sensitive records.

Electronic signatures

Public Act 103-0769, the 2024 amendment, adds "electronic signature" to Section 10's definition of "written release." It defines an electronic signature as an electronic sound, symbol or process attached to or logically associated with a record, executed or adopted with the intent to sign it.

We check the notice, the signed record and the collection date together.

What we found

Each entry connects a device, a supplied record and the next owner decision. Missing records remain open questions.

A

Staff time clock · Sections 15(a), 15(b)

The release file is missing

Records shown

Fingerprint attendance is enabled. The staff file contains a general handbook acknowledgment. It has no biometric collection notice, specific purpose, retention term or biometric release. The supplied policy folder and public policy list contain no biometric retention policy.

Owner action

Have counsel review the notice and release before further collection. Draft a public retention policy for approval. Ask the clock vendor for the first collection date and the complete storage and deletion record.

Keep: the approved policy, the notice version, dated releases and the vendor's written retention answer.

B

Camera app · Sections 15(a) through 15(e)

Face matching has no paper trail

Records shown

The owner's screenshot shows face matching on; the setup sheet marks it as the default. No face-match notice, release or public retention policy is in the supplied file. The agreement does not address deleting templates at contract end or rule out sale, profit or reuse. The manager and vendor support role can export match records, but no disclosure basis is recorded. No written comparison of safeguards with other sensitive records was supplied.

Owner action

Decide with counsel whether face matching should continue. If it is to be turned off, send that decision to the center's licensed integrator. Ask the vendor to identify existing templates, recipients, export rights and deletion options. Turning a feature off leaves the stored-data question open.

Keep: the owner's decision, vendor answers, approved terms and the integrator's record of any system change.

C

Staff door reader · Section 15(b)

Fingerprint enrollment stays off

Records shown

The owner-supplied settings record shows fingerprint enrollment off and badge use on. The enrollment list contains no fingerprint entries. There is no written approval step for enabling fingerprints later.

Owner action

Record the decision to keep fingerprint enrollment off. Put review of the collection notice and release ahead of any future enrollment decision. Route any approved system change to the center's licensed integrator.

Keep: the dated owner decision, current settings record and a named approver for future feature requests.

D

Visitor kiosk · Section 10; Section 15(b) if the data use changes

The photo records are in place

Records shown

The visitor photo notice, photo retention record and center access list are on file. The supplied feature sheet and vendor answer describe photo capture only, with no face matching or face-geometry templates. The current file supports keeping this device separate from the open biometric findings.

Owner action

Keep the vendor's photo-only answer with the inventory. Ask for written notice before a feature update changes how faces are processed, then review the new records before approving its use.

Keep: the vendor answer, photo policy and a record of who approves feature changes.

What the owner does next

Work through the open records in this order. The center owns the decisions and paperwork.

  1. Set the collection decision

    Take the time clock and face-match records to counsel. Record what collection may continue and what should pause. Send any resulting system-change request to the center's licensed integrator.

    Owner: center director

  2. Get the missing data answers

    Send the questions below to the vendors. Add their answers on storage, exports, recipients and deletion to the device inventory.

    Owner: office lead

  3. Approve the retention policy

    Prepare the public written policy and retention schedule with counsel. Ask vendors how their settings and deletion records will support that schedule.

    Owner: center director

  4. Replace the handbook shortcut

    Prepare a separate biometric notice and release for counsel's review. Keep the specific purpose, term, signed version and date together. Record unresolved historical collections separately.

    Owner: staff records lead

  5. Settle the vendor terms

    Request written terms covering sale and profit, permitted uses, disclosure, access safeguards and deletion at the end of service. Approve who can export records and how disclosures will be recorded.

    Owner: center director

  6. Close the review file

    Collect the approved documents, vendor answers and any change records from the licensed integrator. Set a records review whenever a feature, vendor or collection purpose changes.

    Owner: office lead

Questions for the vendor

The owner can send these questions with the relevant device name.

  • What biometric templates or matching records exist, where are they stored, and which organization holds each copy?
  • Who can view or export those records, including support staff and subcontractors? Who has already received them?
  • What do your terms allow you to do with the data, including reuse, sale, trade or use for profit?
  • What happens to existing templates when a feature is turned off or the contract ends? How will you document permanent deletion, including backup copies?
  • What written safeguards protect storage, transmission and disclosure? How do you document feature changes before they affect collection?

Request a records review

Bring the policies, release forms, vendor agreements and settings records you already have. We turn the records into findings and an owner action list.

Discuss a review

Sources

Statute text checked October 30, 2026.

Sample review. Fictional center and records.

This sample is not legal advice.