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How to Limit PII Data in 3rd Party Products

This guide lists 3rd party products that might collect Personally Identifiable Information (PII) on their systems. Where it is possible, instruction is given how to change the product settings to limit or prevent data collection.

PII is defined as: Any representation of information that permits the identity of an individual to whom the information applies to be reasonably inferred by either direct or indirect means.

The integrated systems the NEC Smart Check-In uses that capture and process data include face match systems, scanning systems, and document validation services.

Some vendors require systems to run on-premises and others may run as a cloud-based system.

The perspective provided in this document only covers the NEC Smart Check-In use cases. Other applications using the products and services listed may have other data needs where storage of PII cannot be disabled or limited as mentioned.

Note

External vendors may change data collection policies and methods without NEC's knowledge in current and future versions. Data collection review is encouraged to be performed with the product vendor in question.

Face Match Systems

NEC Smart Check-In integrates with NeoFace Watch and SFA (NeoFace KAOATO).

Face match systems have many use cases. The Smart Check-In has two use cases for using face match systems.

  1. Standard validation for check in and check out: Validate the person using the Kiosk is the same person as the scanned document owner by taking the image from a live camera shot and comparing it to the image from the scanned government issued ID.
  2. Smart Kiosk Recognize Me check in and check out: Lookup a person already registered in the face match system by comparing the stored image from a government issued ID or registration photo with the image from a live camera shot.

If the Smart Kiosk Recognize Me feature is desired to be enabled and used, storing face images and person name in the third-party face match system is unavoidable. The Smart Kiosk Recognize Me feature is not active and usable unless explicitly turned on and the person being registered for the Recognize Me feature consents to the face match system owner (i.e. the hotel) to store their photo. The system owner is responsible for capturing a validated photo and registering the user in the face match system and maintaining and securing the data. Smart Kiosk does not support automatic face registration at this time.

For standard validation for check in and check out, see the descriptions below for each face match system and what PII is captured during standard use of the Kiosk.

SFA (NeoFace KAOATO)

SFA relies on the NeoFace KAOATO application's Web API to perform face comparison. The photos are transmitted from the Kiosk as base-64 serialized strings and, depending on Kaoato's app settings, these strings may appear in some log files.

Image Storage

SFA does not automatically store the images in its image store when performing face match in the standard Kiosk validation case.

Logs

SFA logging defaults to Info level. With Info level logging, base64 image data is not logged.

If log level is set to Trace, base64 image data will be logged on the SFA system in the standard Kiosk validation case.

Note: It is possible to copy the entire base64 image string and have it converted back to a picture image such as a .jpg file.

To check the log level of SFA, do the following:

  • Locate the file "web.config" for NeoFace Kaoato on the SFA server typically found under "C:\inetpub\wwwroot\KaoatoWeb".

  • Open the Web.config using a text editor and locate the key named "rules". Check the minlevel for "KaoatoWeb.*". Confirm the minlevel is set to Info and not Trace to ensure no logging of PII data.

    <rules>
    <logger name="KaoatoWeb.*" minlevel="Info" writeTo="EventLog"/>
    <logger name="NpgsqlNLogLogger" minlevel="Off" writeTo="NpgsqlLog"/>
    <logger name="SemaphoreLogger" minlevel="Off" writeTo="SemaphoreLog"/>
    <logger name="GetNewLogLogger" minlevel="Off" writeTo="GetNewLog"/>
    <logger name="VerifyDelLogger" minlevel="Off" writeTo="VerityDelLog"/>
    <logger name="VerifyWaitLogger" minlevel="Off" writeTo="VerifyWaitLog"/>
    <logger name="LockLogger" minlevel="Off" writeTo="LockLog"/>
</rules>

The log file is located under "C:\inetpub\wwwroot\KaoatoWeb\Kaoato\Log".

NeoFace Watch

Image Storage

NeoFace Watch does not automatically store the images in its image store when performing face match in the standard Kiosk validation case.

Logs

Neoface Watch logging does not log PII data for any log level for the API's used by the Kiosk for face match, there are three different log levels INFO, WARN, and DEBUG.

The log files are typically located in the folder "c:\program files\NEC\NeoFace\Watch\Logs".

To adjust the log level launch the "NeoFace System Configurator" application. Under the Global tab, set the logging selection to the desired log level.

Document validation platforms

E-Visitor Authentication

The E-Visitor Authentication connection is used when required by the Singapore Tourism Board (STB).

Here is the process outlined by STB:

This service is to allow Hotel to send Visitors' data to STB-EVA at the point of check-in.

  1. STB-EVA shall receive a Web Service request from the hotel containing visitor and hotel booking information.
  2. STB-EVA shall validate the request and persist the information in STB-EVA.
  3. STB-EVA shall interface with ICA to process the Visitor and Hotel booking information.
  4. STB-EVA shall return the response to hotel.

Only foreign ID's and passports are to be processed. Local IDs are not sent.

Information sent to STB include all information from the identification as well as the images and selfie photo.

Once data is sent it is assumed stored. It is not possible to turn off logging or storage of this remote system.