Reminder: Colorado Biometric Information Policy Requirement Effective July 1, 2025 - HR ALERTS
- Regina Dyerly, SHRBP, PHR
- Jun 27
- 2 min read
Colorado Biometric Information Policy Requirement Effective July 1, 2025
Effective: July 1, 2025
Applies to:
All employers operating in Colorado who collect biometric information from applicants or employees
Reminder:
As previously shared, starting July 1, 2025, employers in Colorado must meet new requirements under the Colorado Privacy Act when collecting biometric information—including fingerprints, retina scans, or other biological identifiers used for security, timekeeping, or access control.
If your organization collects biometric identifiers, you must have a written biometric policy and a process in place to obtain proper consent from employees and applicants.
What the Law Requires:
1. Written Biometric Policy
Must include:
A biometric information retention schedule
A deletion protocol
A procedure for responding to security breaches
Public availability if the policy applies beyond current employees (e.g., applicants or former staff)
A sample policy is available in the Knowledge Center: https://client.vidahr.com/coloradosp/sample-biometric-data-privacy-and-security-policy
2. Consent Requirements
Employers must obtain consent before collecting biometric identifiers. Consent can be a condition of employment for:
Physical access (e.g., fingerprint scanners)
Securing electronic systems or software
Timekeeping systems
Safety and security-related purposes
Voluntary consent is required for all other uses, and employers cannot retaliate if an employee or applicant declines. Note: Consent obtained during the application process must be renewed upon hire.
A Few Notable Exceptions:
No consent is required if biometric use is clearly expected due to job duties.
No consent is required for biometric data used to complete applications, ID checks, or background screenings.
Get day-to-day updates on Colorado Biometric Information Policy Requirement Effective July 1, 2025 visit the Vida HR Knowledge Center (Vida HR Clients Exclusive).
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