Biometric Data Collection Notice (Client)

How We Verify Your Identity

Before you can be connected with Childcare Professionals on Baby Bloom, we need to verify that you are who you say you are. This notice explains how we use your biometric data during the verification process.

Please read this notice carefully before consenting.

What Data We Collect

During the verification process, we collect:

Facial geometry: We extract measurements of your facial features from the selfie photograph you take during verification.
ID document data: We extract information from your uploaded passport or government-issued ID (name, photo, document number, expiry date).

What We Compare

Your selfie photograph is compared against the photograph on your identity document using AI facial recognition technology. This confirms that the person creating the account is the same person shown on the ID document.

We also verify that your identity document shows a NSW address (if applicable to document type) to confirm your eligibility to use Baby Bloom's services in Sydney.

Overseas Processing and Your Risks

OpenAI (United States): Your biometric data (facial geometry and identity document images) is transmitted to and processed by OpenAI's servers located in the United States (specifically, AWS US-East region).

Data Agreement: Baby Bloom has executed a Data Processing Agreement with OpenAI that requires:

OpenAI to process your biometric data only as instructed by Baby Bloom.
OpenAI to implement security measures to protect your data.
OpenAI to not share your biometric data with third parties without Baby Bloom's consent.
OpenAI to delete your data upon Baby Bloom's instruction.

OpenAI's Privacy Policy: OpenAI has its own privacy policy available at https://openai.com/privacy. You should read it to understand how OpenAI handles data.

US Government Access: Because your biometric data is processed in the United States:

US law enforcement may access your data under court order or warrant.
US intelligence agencies may access your data under FISA (Foreign Intelligence Surveillance Act) Section 702, which allows bulk surveillance of non-US persons' international communications. Unlike Australian law, FISA does not require a warrant or showing of probable cause for foreign persons.
Baby Bloom has no ability to prevent or disclose such access to you — US law prohibits companies from disclosing FISA requests.
The US does not provide the same legal protections as Australian privacy law. Australian Privacy Principles do not apply to US government access.
You have limited recourse if your data is accessed by US authorities. You cannot sue the US government for damages, and you may never know if your data was accessed.

Your Choice: You must consent to overseas processing to use Baby Bloom's connection features. If you do not consent to your data being processed in the United States, you cannot connect with Childcare Professionals on Baby Bloom.

Data Retention at OpenAI: Your biometric data is retained by OpenAI for 7 days after Baby Bloom receives the verification result, then deleted from OpenAI's systems.

Potential Changes to AI Provider: If Baby Bloom changes the AI provider used for facial verification, Baby Bloom will:

Notify all clients via email of the change.
Provide a new Biometric Data Collection Notice specific to the new provider.
Require affirmative consent to the new provider before using their data.

Until you affirmatively consent to the new provider, your account will be suspended (you will not be able to connect with new Childcare Professionals). If you do not consent within 30 days, Baby Bloom may close your account.

How AI and Human Review Work Together

AI Facial Matching: Baby Bloom uses OpenAI facial recognition (GPT-4o or similar) to compare your selfie against your ID photo. The AI produces a “match score” (0-100%, indicating confidence that the selfie matches the ID photo).

Flagging Threshold: Cases with a match score below 85% are flagged for human review. This threshold was chosen to ensure high confidence matches bypass manual review, while borderline cases receive human assessment.

Human Review: A Baby Bloom staff member reviews flagged cases manually. The human reviewer:

Compares your selfie and ID photo themselves.
Considers factors the AI may have missed (lighting, angle, facial hair, age, natural aging, makeup, etc.).
Makes the final VERIFICATION DECISION (approved or rejected).
Is not bound by the AI's match score; human judgment overrides AI.
If a case is approved despite AI match score below 85%, the human reviewer documents their reasoning.

No Automatic Bias: Baby Bloom does not use AI match score alone to reject applicants. If your case shows a lower match score due to age, gender, ethnicity, or other factors, it will receive manual human review before rejection.

Audit Trail: Baby Bloom records:

The date of your verification.
The AI match score and flagging decision.
Whether your case was manually reviewed.
The human reviewer's name (or ID) and decision.
The date and time of all decisions.
Any notes or reasons for rejection or approval.

Access to Your Records: You can request a copy of your verification audit trail (including the AI match score, flagging decision, and human reviewer's notes) at any time by contacting compliance@babybloomsydney.com.au. Baby Bloom will respond within 10 business days.

Appeal Process: If your verification is rejected, you can contact Baby Bloom within 14 days to request:

A detailed explanation of why you were rejected, including the AI match score and reviewer notes.
A manual review by a different staff member (senior to the original reviewer).
A copy of your AI match score and any notes made by reviewers.
Baby Bloom will provide a written response within 7 business days of receiving your appeal request.

How Long We Keep Your Identity Verification Data

Your Biometric Data (Facial Geometry):

While your account is active: Retained for the life of your account.
After account closure: Permanently deleted 90 days after closure.

Your Identity Documents (Passport, Driver's License):

While your account is active: Retained for the life of your account.
After account closure: Permanently deleted 90 days after closure.

Your Verification Result (What Baby Bloom Keeps Permanently):

Baby Bloom retains the following information permanently, even after account closure, in de-identified form (meaning it is not linked to your name or personal account):

Document type verified (e.g., “Australian Passport”)
Document number (last 4 digits only, no full number)
Verification outcome (approved/rejected, not name-linked)
Verification date
AI match score (but not linked to your identity)

Purpose of Permanent Retention: This information is retained for:

Fraud prevention: To identify patterns of document reuse across multiple accounts, without identifying the individuals.
Regulatory compliance: To maintain records in case of government childcare regulator inquiries about our verification procedures.
System improvement: To measure AI system accuracy and bias across different demographics.
Dispute resolution: To resolve disputes about whether a verification decision was made fairly (if needed, we can re-identify the record only with your explicit consent).

Your Rights and Consequences of Withdrawing Biometric Consent

You have the right to:

Access: Request access to the biometric data we hold about you at any time.
Deletion: Request deletion of your biometric data. Please note that if your biometric data is deleted, you may need to complete the verification process again to continue using the Platform.
Withdraw consent: You may withdraw your consent for biometric data processing at any time.

However, withdrawing consent means:

Your connection features will be immediately suspended. You will not be able to:
- Request interviews with new Childcare Professionals.
- Post new babysitting requests.
- View or communicate with Childcare Professionals you have not already hired.
Active care arrangements are NOT affected. If you are already working with a Childcare Professional, withdrawal of biometric consent does not terminate your care arrangement with them. Baby Bloom does not manage or control active care arrangements — those are separate contracts between you and the Childcare Professional.
Your account can be reactivated. If you withdraw consent and later change your mind, you can request reactivation. Baby Bloom will re-verify your identity and you must re-consent to biometric processing before your account is reactivated.
Data deletion upon withdrawal. If you withdraw consent, your biometric data is deleted immediately. Your verification results remain in de-identified form.
Timeline: Withdrawal takes effect immediately upon request. Any pending verification requests are cancelled.

To exercise any of these rights, contact:

Email: compliance@babybloomsydney.com.au

Baby Bloom will respond within 30 days.

What If Your Verification Is Rejected?

If Baby Bloom notifies you that your verification has been rejected, you have the right to:

Request a detailed explanation within 7 days. Baby Bloom will provide:
- The reason for rejection (e.g., “facial geometry did not match ID photo,” “document was not authentic,” “verification flagged as suspicious”).
- The AI match score (if applicable).
- Notes made by any human reviewers.
Request re-verification at any time:
- You can submit a new selfie and/or new identity documents.
- Re-verification is free (no additional charge).
- Re-verification uses the same process as your original verification.
- Re-verification can be requested up to 3 times. After 3 rejections, contact Baby Bloom support to discuss further options.
Request manual escalation if you believe the rejection was unfair:
- Contact compliance@babybloomsydney.com.au with the subject “Verification Appeal.”
- A senior Baby Bloom staff member (not the original reviewer) will review your case.
- This escalation should take no more than 7 business days.
- You can submit additional documents or evidence supporting your appeal.
Lodge a complaint if you are not satisfied with the appeal outcome:
- Contact the OAIC at www.oaic.gov.au (if you believe your privacy has been breached).

Security of Your Biometric Data

In Transit: Your biometric data (selfie and ID photos) are encrypted using TLS 1.2+ when transmitted to OpenAI's servers.

At Rest: Your biometric data is encrypted in Baby Bloom's and OpenAI's databases using AES-256 encryption.

Access Controls: Only authorised Baby Bloom staff with a specific business need (e.g., fraud investigation, verification review) can access your biometric data. Access is logged and audited.

Incident Response: If Baby Bloom discovers a security breach involving biometric data, Baby Bloom will:

Notify affected clients within 30 days.
Provide free credit monitoring or identity theft protection services.
Cooperate with law enforcement and the OAIC.

Legal Basis for Biometric Verification

Baby Bloom requires biometric verification under Australian Privacy Principle 3.3, which permits collection of sensitive information (including biometric data) with your express consent.

This verification is necessary to confirm your identity before connecting you with Childcare Professionals who will be caring for your children.

This is not optional — if you do not consent to biometric verification, you cannot use Baby Bloom's connection features.

Liveness Detection and Spoofing Prevention

When you submit your selfie, Baby Bloom uses “liveness detection” to confirm that the selfie is of a real, live person (not a printed photo, video, or mask).

Your selfie must be taken in real-time using your device's camera during the verification process. You cannot use a stored photo from your phone.

What Is Facial Geometry?

“Facial geometry” is a mathematical representation of your face — specifically, the measurements and positions of key facial features such as:

Distance between your eyes.
Shape and size of your nose.
Shape of your jawline.
Distance from your chin to your forehead.

Facial geometry is NOT a photograph. It is a set of numbers and measurements. This is important because:

The AI cannot use facial geometry to create a new photo of your face.
Facial geometry is smaller and faster to process than a full photograph.
Facial geometry is more resistant to changes in lighting or angle.

Complaints About Your Privacy Rights

If you believe Baby Bloom has breached your privacy rights under the Privacy Act 1988, you can lodge a complaint with:

Office of the Australian Information Commissioner (OAIC)

Website: www.oaic.gov.au
Phone: 1300 363 992

Baby Bloom, Sydney
ABN: 17 463 812 867
Compliance: compliance@babybloomsydney.com.au