BIOMETRIC DATA RETENTION & DESTRUCTION POLICY

Effective: 9/1/2026

Scope. This Policy covers the retention and destruction of any Biometric Data in the possession of Delta Dental Plans Association, DeltaUSA and DeltaWellness Inc. (together, “DDPA”).  Biometric Data means a retina or iris scan, fingerprint, voiceprint, scan of hand or facial geometry, and any information based on these identifiers that is used to identify an individual, as further defined by Illinois law.

Retention (ordinary course). Biometric Data, if any, will be permanently destroyed when the initial purpose for collection is satisfied or within 3 years after the individual’s last interaction with DDPA, whichever occurs first.

Litigation hold / preservation. If DDPA reasonably anticipates litigation, receives a preservation request, or issues or is subject to a litigation hold, DDPA will preserve relevant data and suspend deletion in accordance with the hold, until Legal lifts the hold. After lift, destruction resumes under this Policy.

Destruction method. Destruction will be performed to render Biometric Data unreadable and unrecoverable (including by directing service providers to delete where applicable), except where retention is required by law or hold. 

No sale. DDPA does not sell, lease, trade, or otherwise profit from Biometric Data.

Questions. Please contact Delta Dental Plans Association, 222 W. Merchandise Mart Plaza, Suite #631, Chicago IL 60654, Attention:  Law Department.