Data Retention & Destruction Schedule

This is ELPReady's publicly available written policy establishing the retention schedule and destruction guidelines for biometric identifiers and biometric information, as required by applicable biometric privacy laws, including the Illinois Biometric Information Privacy Act (BIPA).

What We Collect

During an English Language Proficiency (ELP) assessment, we collect from the assessment taker:

• Voice recordings of spoken responses to each assessment question, and a short microphone-calibration recording
• Facial video recordings of the assessment taker while answering (only when enabled by the taker's carrier)
• Speaker-analysis data derived from the voice recordings, used solely to confirm a single person completed the assessment

Each item above may constitute a biometric identifier or biometric information under applicable law and is collected only after the assessment taker receives written notice and provides a written release at the start of the assessment.

Retention Schedule

Data Category	Retention Period	Destruction Method
Assessment voice recordings (audio)	Destroyed within 1 year of assessment completion	Permanent deletion from production storage by automated daily process
Assessment video recordings	Destroyed within 1 year of assessment completion	Permanent deletion from production storage by automated daily process
Microphone-calibration recordings	Destroyed within 1 year of assessment completion (or of collection, for assessments never completed)	Permanent deletion from production storage by automated daily process
Speaker-analysis (voice-analysis) data	Destroyed within 1 year of assessment completion	Permanent deletion from the production database by automated daily process
Written transcripts, scores, and pass/fail results	Retained as employment-qualification records (contain no biometric data)	N/A - retained per carrier compliance requirements
Consent releases and destruction audit records	Retained as legal proof of compliance (contain no biometric data)	N/A

In all cases, biometric data is destroyed no later than the earlier of (a) the schedule above, or (b) within a reasonable time after the initial purpose for collection has been satisfied, and never later than 3 years after the assessment taker's last interaction with the service.

Earlier Destruction

• When a carrier deletes a driver from the service, all of that driver's recordings and speaker-analysis data are permanently destroyed immediately, ahead of the schedule above.
• Assessment takers may request earlier destruction of their biometric data by contacting us or their carrier; requests are honored subject to applicable legal requirements.

Third-Party Processing

To transcribe and analyze recordings, audio is transmitted to third-party speech-processing providers acting on our behalf under confidentiality obligations, solely to perform transcription and speaker analysis. We do not sell, lease, trade, or otherwise profit from biometric data, and we do not disclose it except to the assessment taker's carrier, to our speech-processing service providers, or as required by law. See our Privacy Policy for the current list of providers.

Deletion of Personal Information (CCPA)

Separate from the biometric schedule above, an assessment taker may request deletion of their personal information. On a verified request, we anonymize the driver's identifying details, delete their recordings, and scrub their assessment transcripts, retaining only de-identified pass/fail results and the records we are required or permitted to keep by law (the biometric-consent release and immutable audit trail). Because ELPReady acts as a service provider to carriers, driver requests are coordinated through the driver's carrier; contact us at the address below and we will assist.

Destruction Verification

Every automated destruction event is recorded in an immutable audit log (what was destroyed and when, without retaining any biometric content), providing a verifiable record that this schedule is followed.

Contact

Questions about this schedule or destruction requests: privacy@elpready.com