Policy on Biometric Technology

This policy is intended to advise employees and temporary staff of the nature and extent any system in use by I-CAR (the "Company") uses information which may be considered biometric information or biometric identifiers subject to the Illinois Biometric Information Privacy Act ("BIPA"), 740 ILCS 14/1, et seq.

To assist with the creation of training videos, the Company uses voiceprint technology by Eleven Labs in the recording of an employee’s voice.  The voiceprint is captured using existing recordings of a voice.  Once the recording is uploaded, speech synthesis artificial intelligence will create or replicate a voice using a mathematical algorithm.  This algorithm and process will then be used to create voice recordings for training videos.  This policy is applicable to the Eleven Labs AI system in use by the Company.


  1. The Company will not disclose, redisclose or disseminate the voice print or data derived from the voice print to anyone other than the vendor (currently, Eleven Labs) providing the technology for the purposes identified above, as well as the licensed delivery partners of the Company that may use the training videos developed with the voice print technology.  The voice print or data derived from the voice print (i.e. digital training course) will be stored with the Company in the digital asset management server, as well as in cloud storage utilized by the vendor (Eleven labs) via their website.
  2. The Company will not sell, lease, trade, or otherwise profit from the voice print or data derived from the voice print outside of its normal business operations of delivering educational training services to its customers in the inter-industry.  Additionally, the Company may pay a vendor (s) for the technology or for services arising out of or relating to the technology utilized by the Company.

Retention and Destruction Guidelines

The voice print and/or data derived from the voice print (i.e. the mathematical algorithm), as well as the digital training courses created from the technology, will be stored during the term of an employee’s employment with Company.  If the employee’s employment continues for three years or longer after the voice print and/or data derived from the voice print was first obtained, the employee will be provided with an opportunity to update his/her consent and release.  In the event of termination of the employee’s employment, the voice print and/or mathematical algorithm will be destroyed by the Company within 90 days of the termination date.   The trainings that were narrated using the voice print prior to the date of termination will be maintained by the Company.

Storage, Transmission and Protection

The Company shall use a reasonable standard of care to store, transmit and protect from disclosure the unique number derived from the employee’s voice print and/or data.  Such storage, transmission, and protection from disclosure shall be performed in a manner that is the same as the manner in which the Company stores, transmits and protects from disclosure confidential and sensitive information, such as account numbers, PINs, driver’s license numbers and social security numbers.