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Biometric Data Retention & Destruction Policy

Last Updated: June 19, 2026

This Biometric Data Retention & Destruction Policy ("Policy") explains how ConsultMeIn LLC, doing business as SkillIQ ("we", "us"), collects, uses, stores, retains, and permanently destroys biometric identifiers and biometric information. It is designed to support the Illinois Biometric Information Privacy Act (BIPA), the EU GDPR (Article 9), India's DPDP Act 2023, and UAE/Singapore PDPL/PDPA.

1. What We Collect

During AI video interviews and anti-cheating monitoring, we may capture and process facial imagery and related biometric identifiers for the limited purpose of verifying a candidate's presence and identity and deterring impersonation/cheating.

2. Lawful Basis & Consent

We collect biometric data only after obtaining the individual's explicit, written, informed consent, captured electronically before any biometric processing begins. Consent records (including timestamp and policy version) are retained as evidence of compliance. Individuals may decline; declining means the biometric-based interview cannot proceed, and alternatives may be arranged with the recruiter.

3. Purpose Limitation

Biometric data is used solely for identity/presence verification and interview integrity. We do not use it for any other purpose, and we do not use it to train or improve AI models.

4. No Sale or Disclosure for Profit

We do not sell, lease, trade, or otherwise profit from biometric data. We disclose it only: (a) to the recruiting organisation that invited the candidate, (b) to service providers strictly necessary to deliver the service, or (c) where required by law or valid legal process.

5. Retention Schedule

  • Biometric identifiers are retained only as long as necessary to fulfil the purpose for which they were collected and to support the related hiring decision.
  • In all cases, biometric data is permanently destroyed on the earlier of: (i) the date the purpose has been satisfied, or (ii) within 3 years of the individual's last interaction with us, consistent with BIPA's maximum retention limit.
  • Where stricter limits apply under local law, the stricter limit governs.

6. Destruction Method

Upon expiry of the retention period, biometric data is permanently and irreversibly deleted from production systems and backups using secure deletion methods, such that it cannot be reconstructed or recovered.

7. Security Safeguards

Biometric data is encrypted in transit (TLS) and at rest, access is restricted on a least-privilege basis, and access is logged and monitored.

8. Your Rights

You may withdraw consent, request access, or request deletion of your biometric data at any time by submitting a request via our Data Request form or by emailing our Data Protection Officer.

9. Contact

Data Protection Officer — ConsultMeIn LLC (dba SkillIQ)

Email: contact@consultmein.com