Privacy Policy — UP BOCW Attendance Mobile App

1Introduction

This Privacy Policy explains how the UP BOCW Attendance Mobile App ("we", "us", "our", "the App") collects, uses, stores, and protects information relating to workers, supervisors, employers, and contractors using our AI-based face recognition attendance system. The App is designed to support daily attendance marking for construction workers on registered worksites and to assist employers/contractors in maintaining attendance records consistent with the requirements of the Uttar Pradesh Building and Other Construction Workers Welfare Board (UP BOCW), constituted under the Building and Other Construction Workers (Regulation of Employment and Conditions of Service) Act, 1996 and the Building and Other Construction Workers' Welfare Cess Act, 1996.

Worker registration/beneficiary data, Shramik (labour) card details, and welfare scheme enrollment referenced within the App correspond to records maintained on the official UP BOCW portal. The App does not operate, own, or control the UP BOCW government portal. For official registration, renewal, scheme applications, and grievance redressal directly with the Board, please visit the official UP BOCW website: https://website.upbocw.in/.

By registering on the App, enrolling your face for attendance, or otherwise using our services, you agree to the collection and use of information as described in this Privacy Policy. If you do not agree with this policy, please do not use the App.

2Information We Collect

We collect information in the following categories to enable attendance tracking, labour registration, and payroll compliance:

Category	Examples
Personal identification data	Full name, gender, date of birth, phone number, address, Aadhaar number / government ID number (where required for UP-BOCW registration), photograph
Biometric data	Facial images and mathematically derived facial embeddings/templates used for identity verification and anti-spoofing (liveness detection)
Employment & attendance data	Employer/contractor name, site/project location, punch-in and punch-out timestamps, shift details, wage category
Device & technical data	Device model, OS version, app version, device identifiers, IP address, crash logs
Location data	GPS coordinates captured at the time of attendance punch, to verify the worker was present at the registered worksite
Camera & media data	Live camera feed/captured images used only for face enrollment and attendance verification

3Biometric (Face) Data — Special Notice

Important: Facial recognition data is sensitive personal information. We process it only for the purpose of identity verification and attendance marking, with your explicit consent obtained at the time of enrollment.

Specifically:

Face images are captured only during enrollment and each attendance punch — not continuously or in the background.
We use on-device or server-side processing (InsightFace-based recognition with liveness/anti-spoofing checks) to convert facial images into a numeric template. The raw image may be discarded or securely stored depending on the deployment configuration.
Facial templates are used solely to match a worker's identity against their enrolled record for attendance purposes — never for tracking individuals outside the attendance workflow, advertising, or any unrelated purpose.
Facial data is never sold, rented, or used for any commercial purpose unrelated to attendance and labour compliance.
You may request deletion of your biometric data at any time, subject to statutory record-keeping obligations under applicable labour laws (see Section 8).

4Relationship with UP BOCW

The App is used to record daily attendance of registered construction workers at worksites, which employers/contractors may use to support wage computation, cess compliance, and reporting obligations under the Building and Other Construction Workers (Regulation of Employment and Conditions of Service) Act, 1996, as administered in Uttar Pradesh by the UP BOCW Welfare Board (official portal: website.upbocw.in).

Worker names, Aadhaar-linked identity details, and Shramik/labour card numbers entered in the App may correspond to a worker's existing registration on the official UP BOCW portal — the App does not itself perform UP BOCW beneficiary registration, renewal, or scheme applications.
Attendance data captured by the App (worksite, date, time, verified identity) may be shared with the relevant employer, contractor, or Labour Department office where required to demonstrate compliance with statutory record-keeping and cess obligations under the BOCW Act.
We are an independent technology provider and are not an agent, representative, or official partner of the Government of Uttar Pradesh or the UP BOCW Welfare Board unless separately stated in writing.
The name "UP BOCW Attendance Mobile App" describes the App's purpose — recording attendance for workers covered under the UP BOCW scheme — and is not intended to represent, and should not be construed as representing, that this App is owned, operated, or endorsed by the Government of Uttar Pradesh or the UP BOCW Welfare Board.
For all official matters — registration, renewal, scheme benefit applications, certificate downloads, application status, or grievances — workers should use the official UP BOCW portal at https://website.upbocw.in/ or contact their local Labour Office directly.

5How We Use Your Information

To verify worker identity and mark accurate attendance (punch-in/punch-out)
To register workers under UP-BOCW / labour welfare schemes as required by the employer or government authority
To generate attendance, wage, and compliance reports for employers/contractors
To prevent proxy attendance and fraud through liveness/anti-spoofing detection
To provide customer support and resolve technical issues
To comply with applicable labour laws, welfare board regulations, and government reporting requirements
To improve the accuracy and reliability of our recognition system (using de-identified or aggregated data wherever possible)

6Legal Basis & Consent

We process personal and biometric data based on your explicit consent, given at the time of registration/enrollment, and/or as necessary to comply with legal obligations under labour welfare laws (including UP-BOCW rules), and to fulfil the contract between the worker, the employer/contractor, and the App.

Consent for biometric enrollment is collected separately and clearly at the time of face registration. You may withdraw consent at any time, which may result in the App being unable to mark your attendance via facial recognition (an alternative manual attendance method may be offered by your employer, where available).

8Data Storage & Security

Data is stored on secure servers with encryption in transit (HTTPS/TLS) and, where applicable, encryption at rest.
Access to biometric and personal data is restricted to authorized personnel on a need-to-know basis.
Face recognition processing devices (including Raspberry Pi-based edge devices deployed at worksites) are configured to transmit only authenticated, verified attendance events to our servers.
We use anti-spoofing/liveness detection to prevent the use of photos, videos, or masks to fake attendance.
Despite our best efforts, no method of transmission or storage is 100% secure. We continuously work to improve our security practices.

9Data Retention

We retain personal, attendance, and biometric data for as long as your account is active, or as long as required to fulfil the purposes described in this policy, or as mandated by applicable labour welfare laws and statutory record-keeping requirements (which may require retention for a defined number of years after the end of employment). Once the retention period lapses, data is securely deleted or anonymized, unless a longer retention period is required by law.

10Your Rights & Choices

Subject to applicable law, you have the right to:

Access the personal data we hold about you
Request correction of inaccurate or incomplete data
Request deletion of your data, including biometric templates, subject to statutory retention obligations
Withdraw consent for biometric processing at any time
Raise a complaint regarding how your data is handled

To exercise these rights, please contact us using the details in Section 14.

11Children's Privacy

The App is intended for use by adult workers and administrative personnel only. We do not knowingly collect data from individuals under the legal working age. If we become aware that we have inadvertently collected data from a minor, we will take steps to delete such data promptly.

12App Permissions

Permission	Why we need it
Camera	To capture face images for enrollment and attendance verification
Location	To confirm the worker is present at the registered worksite at the time of attendance
Storage	To temporarily cache attendance data and images before secure upload
Internet/Network	To sync attendance and registration data with our secure servers

You may disable these permissions via your device settings; however, doing so may prevent core App features from functioning.

13Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify users of material changes via the App or by updating the "Last Updated" date at the top of this page. Continued use of the App after changes constitutes acceptance of the revised policy.

14Contact Us

Data Controller: UP-BOCW Board

App Name: UP BOCW Attendance Mobile App

Email: upbocboardlko@gmail.com

Address: 2nd फ्लोर, ए & डी ब्लाक, किसान मंडी भवन, विभूति खंड, गोमती नगर, लखनऊ - 226010