Biometric Information Policy

With consent, we create a “faceprint”, a set of measurements of the child’s facial geometry, from a reference photo of the child. The reference photo can come from the family portal, the registration form, or the camp’s staff. A faceprint is a biometric identifier under the laws of several states. We do not collect fingerprints, voiceprints, retina or iris scans, or any other biometric identifier.

Only to find the camp photos a child appears in, so they can be shared with that child’s family. Faceprints are never used for security, surveillance, attendance, check-in, discipline, marketing, advertising or profiling. A faceprint is never sold, leased or traded, and no one is paid for access to it.

• No faceprint is created until a parent or legal guardian has answered Yes to the camp’s facial-recognition consent. That consent is a written release, signed electronically.
• The newest answer on file is the one that counts. If it is anything other than Yes, no faceprint is made, and any existing faceprint is deleted (see section 6).
• Because the consent is given by the child’s parent or guardian, it also serves as the parental consent required for children under 13.
• Saying No does not affect the child’s enrollment or the family’s ability to receive camp photos.

To find a child in camp photos, each photo is compared against the faceprints of children whose families said Yes. Faces in the photo that match none of those children, including other campers, staff and visitors, are not stored and are not identified. For a match we keep only which photo, which child, where in the photo, and how confident the match was.

The camp and Core Registration. Core stores faceprints in encrypted form with its cloud provider, Amazon Web Services (Rekognition), which acts on our behalf under contract solely to perform the matching. Each camp’s faceprints are kept in a separate collection and are never shared with, or matched against, another camp’s. We do not disclose faceprints to anyone else unless the parent asks us to, or the law, a subpoena or a court order requires it.

Matching runs for every consented child. A family sees the matched photos for a session once Face Finder is turned on for that session in the family portal, which may carry a fee for the photo-finding service. The fee pays for the service. It does not buy the faceprint, or access to it.

A child’s faceprint, and the record of which photos matched, are permanently deleted at the earliest of:

• Consent withdrawn. Deleted when the consent is withdrawn or replaced by an answer other than Yes, and in every case within 30 days.
• 12 months after the child’s last session. Measured from the end of the most recent session the child was registered for at that camp. For a child never registered for a session, it is measured from when the reference photo was provided.
• The camp stops using the feature. Every faceprint the camp holds is deleted.
• The reference photo or the child’s record is removed.

We never keep a faceprint longer than 3 years after the parent’s last interaction with the camp, or after the initial purpose has been satisfied, whichever comes first. The schedule above is always shorter.

An automated job runs every day. It deletes each faceprint that the schedule above no longer allows us to keep, from Amazon Rekognition and from our database, together with that child’s photo matches. The same job deletes anything in a camp’s collection that no consented child owns. Deleted faceprints cannot be recovered or recreated.

You may choose to be notified when new photos matched to your child are posted. If you turn alerts on:

• We batch notifications and send them a few times per day — not one message per photo.
• Every alert links you to your secure family portal. We never attach or embed the photo itself, because photos of your child often include other families.
• You choose the channel — email, text message, or both.
• You can turn alerts off at any time from the Photos section of your portal.

If you opt in to text alerts: message frequency varies, and standard message and data rates may apply. Reply STOP to any message to cancel text alerts, or HELP for help. Opting out of texts does not affect email alerts or your portal access.

You may withdraw consent at any time by contacting the camp office, and the faceprint is then deleted as described in section 6. Depending on where you live, you may have additional rights to access or delete biometric and personal information. See our Privacy Policy, or contact privacy@coreregistration.com.