Privacy Policy

DRAFT for Gert's approval. Not yet reviewed by a lawyer. Text in [square brackets] must be completed.

Last updated: 9 November 2026

This policy explains how ClockMeIn Time and Attendance, operated by [legal entity name] ("we"), handles personal information, as required by the Protection of Personal Information Act 4 of 2013 (POPIA). Information Officer: [name], [email].

1. Two kinds of information

Customer account information, such as the names, emails and phone numbers of the people who sign up and use the admin screens, and company details. For this information we are the responsible party.
Employee information that our customers put into ClockMeIn: employee names and numbers, face templates, clock-in times and snapshot photos. For this information the employer (our customer) is the responsible party and we are its operator. Employees should direct requests about their information to their employer first.

2. What we process about employees, and why

Face template: a list of 1,024 numbers calculated from the employee's face at enrolment. It is used only to recognise the employee at their employer's kiosk. We do not store the enrolment photos. The template is calculated on the tablet and cannot be turned back into a photograph.
Clock events: the date and time, IN or OUT, site and kiosk, and the match score.
Snapshot: a small photo taken at each clock-in, so the employer can check who clocked in. Snapshots are deleted automatically after the employer's retention period (90 days by default, between 7 and 730 days).
Name, employee number and site, as entered by the employer.

Biometric information is special personal information. It is processed with the employee's consent, which is recorded at enrolment (POPIA sections 26 and 27(1)(a)), and only for time and attendance.

3. Where face recognition happens

Faces are detected, and the liveness and anti-spoof checks run, on the kiosk tablet in the browser. Only the numeric template, the liveness scores and the snapshot are sent to our server over an encrypted (HTTPS) connection. Our server compares the template only with the employees of the same employer. We do not use any third-party face-recognition service.

4. Security

Encrypted connections (HTTPS) for all traffic.
Each customer's data is kept separate from other customers' data, and every request checks it.
Snapshots are stored outside the public web folder and can only be opened by the employer's admins.
Passwords are stored as one-way hashes. Kiosk tablets use revocable device tokens.
Servers are hosted in [South Africa, provider]. Daily backups are kept for 14 days.

5. Sharing

We do not sell personal information. We share it only with service providers who help us run ClockMeIn (hosting, email delivery) and who are bound to protect it, or when the law requires it.

6. Retention and deletion

A face template is deleted when the employer deactivates the employee or deletes the enrolment.
Snapshots are deleted after the retention period.
Clock events are kept for as long as the employer's account is open, because employers need them for payroll and labour-law records.
After an account is closed, all its data is deleted after [90] days, or sooner on written request.

7. Your rights

You may ask for access to your personal information, ask for it to be corrected or deleted, object to processing, and withdraw consent. Withdrawing consent does not affect processing that took place before. Employees should contact their employer, who can delete the face template in ClockMeIn immediately. You can also contact our Information Officer. You may lodge a complaint with the Information Regulator (South Africa): inforegulator.org.za.

8. Cookies

We use only essential cookies: a login session cookie for admin users and a device cookie that keeps a kiosk tablet paired. We do not use advertising or tracking cookies.