The policy authorizes ADP to process biometric data including fingerprints for asset protection, site and system access, security, and fraud prevention purposes without requiring prior explicit consent for these listed uses.
This analysis describes what ADP's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision authorizes biometric data processing — a category subject to heightened regulatory requirements under statutes such as the Illinois Biometric Information Privacy Act — for enumerated business purposes under the BCR framework, with prior explicit consent required only for uses beyond those listed categories.
Interpretive note: The extent to which the BCR framework satisfies US state-level biometric consent requirements such as BIPA is not addressed in the document and depends on jurisdiction-specific legal analysis.
ADP deleted the cookie preference management tool that previously allowed users to understand and control which cookies were placed on their devices, including functional, analytics, and advertising cookies. The removal eliminates the transparency mechanism through which users could consent to or opt out of different cookie categories. The practical effect depends on whether ADP has replaced this functionality elsewhere or whether cookies continue to be placed without equivalent granular user control.
View change record →Under this clause, ADP may collect and process biometric identifiers such as fingerprints for site access and security purposes. Individuals whose biometric data is processed for purposes beyond those listed would be entitled to prior explicit consent under the terms of the policy.
Cross-platform context
See how other platforms handle Biometric Data Processing and similar clauses.
Compare across platforms →"Biometric data (such as fingerprints). ADP may Process biometric data for the protection of ADP and Staff assets, system and site access, security and fraud prevention reasons.Excerpt from ADP's Privacy Statement
REGULATORY LANDSCAPE: This provision engages the Illinois Biometric Information Privacy Act (BIPA), which requires written informed consent before collecting biometric identifiers, a publicly available written retention schedule, and prohibits sale or profit from biometric data.
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This provision authorizes biometric data processing — a category subject to heightened regulatory requirements under statutes such as the Illinois Biometric Information Privacy Act — for enumerated business purposes under the BCR framework, with prior explicit consent required only for uses beyond those listed categories.
Under this clause, ADP may collect and process biometric identifiers such as fingerprints for site access and security purposes. Individuals whose biometric data is processed for purposes beyond those listed would be entitled to prior explicit consent under the terms of the policy.
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