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Applicant Biometric-Related Information Privacy Notice

Effective Date: September 28, 2026

West Monroe Partners, LLC and its affiliates (collectively, “West Monroe” or the “Company”) may ask applicants for employment with West Monroe (collectively, “Applicants”) to complete identity review during the application process, including through identity review providers, such as CLEAR and Socure. Identity review is intended to help confirm that an Applicant is the person they claim to be, reduce candidate impersonation and application fraud, and protect West Monroe, its clients, systems, personnel, and recruiting process.

Depending on the identity review provider and the stage of the application process, identity review may involve submission of a government-issued identification document, a selfie or liveness image, facial recognition or face geometry analysis, device or application signals, and related verification results or status information (collectively, “Identity Review Information”). Identity Review Information may include BRI (as defined below) where the information is a biometric identifier, biometric information, biometric data, or biometric-derived information. Applicants may contact Talent Acquisition to request technical support, a new verification link, additional time, an opportunity to provide additional information, appeal of an adverse decision, or an accommodation in connection with the identity review process. A negative, failed, unable-to-complete, declined, expired, or unresolved identity review result is not an automatic rejection and will be routed for documented human adjudication before any final adverse decision is made based materially on that result. If the Applicant later appeals an adverse decision, West Monroe will conduct appeal review where available under applicable law or West Monroe policy.

West Monroe established this Notice and Consent to inform Applicants about the collection, storage, use, disclosure, retention, and destruction of BRI and Identity Review Information in connection with identity review and to ensure such information is reasonably safeguarded and not retained for longer than is necessary. This Notice and Consent is intended to comply with all potentially applicable laws including, but not limited to, the Illinois Biometric Information Privacy Act (“BIPA”) and comparable state laws. To the extent West Monroe receives or possesses any BRI, this Notice, together with West Monroe’s applicable records retention schedules, constitutes West Monroe’s written policy establishing a retention schedule and guidelines for permanently destroying such BRI.

Definition of Biometric-Related Information

Under this Notice, the phrase “BRI” is used to include, but is not limited to, all potentially applicable legal definitions of “biometric data,” “biometric identifiers,” or “biometric information,” and any information that is derived therefrom. The phrase “BRI” is used in this Notice to include, but is not limited to, data generated from a scan of a finger, retina or iris, facial scan, fingerprint, voiceprint, liveness image, selfie, face geometry, biometric template, or other biometric-derived information. For purposes of this Notice, biometric-derived information used to verify identity during the application process is referred to as “BRI” even though it may not meet the definition of “biometric data,” “biometric information,” or “biometric identifiers” under applicable law. Other information processed in connection with identity review, including government-issued identification documents, device or application signals, limited identifiers, verification results or status information, reviewer notes, Applicant submissions, and appeal records, is referred to as “Identity Review Information” and is treated separately unless it constitutes BRI under applicable law or this Notice and Consent.

Identity Review and Collection of BRI

If an Applicant is asked to complete identity review, the Applicant may be asked to submit information directly to an identity review provider, such as CLEAR or Checkr. Depending on the provider and review, the provider may collect, capture, store, or otherwise process Identity Review Information, including BRI where applicable, a selfie or liveness image, face geometry, biometric template, government-issued identification document, device information, application information, and related verification result or status information.

The applicable identity review provider may present separate privacy notices, biometric notices, consents, authorizations, or terms that govern the provider's direct collection, analysis, use, retention, disclosure, and deletion of BRI and Identity Review Information.

West Monroe does not intend to receive or store Applicants' biometric templates, selfie or liveness images, or government-issued identification documents, except as otherwise disclosed or as permitted or required by law or legal process.

West Monroe or its service provider will obtain a written release/consent, as applicable, from Applicants before BRI is collected. The release/consent will inform Applicants about the BRI and Identity Review Information that may be collected, stored, used, or disclosed in connection with identity review, the specific purpose of the identity review, the length of time for which BRI may be collected, stored, and used, and the identity review providers involved. West Monroe will not collect BRI from an Applicant who has not provided a written release.

Use, Access, and Disclosure

West Monroe may request identity review and may receive and use Identity Review Information and related verification result information for identity review, application integrity, fraud prevention, background check administration where applicable, human review and appeal, documentation, audit, legal compliance, security, and support purposes. To the extent West Monroe receives or otherwise processes BRI, West Monroe may use it only for those purposes. The Company does not intend to receive or store Applicants' biometric templates, selfie or liveness images, or government-issued identification documents from identity review providers, including CLEAR and Checkr as applicable, except as otherwise disclosed or required by law, legal process, or Company procedure.

West Monroe may receive limited verification result data, such as pass, fail, incomplete, expired, declined, unresolved, or similar status information, limited identifiers, and related information needed to support the identity review workflow. West Monroe will not sell, lease, trade, or otherwise profit from BRI. West Monroe will not disclose BRI or Identity Review Information to any third parties other than identity review providers, including CLEAR (through Greenhouse) and Socure (through Checkr) as applicable, background check providers, applicant tracking system providers, professional advisors, and Company personnel or other service providers with a need to know, as necessary to (1) perform identity review, support the application or background check process, assist West Monroe with compliance, conduct audits and investigations, provide related services, or as otherwise permitted or required by law or legal process, or (2) provide technical support, security, administration, or similar services. The applicable identity review provider, including CLEAR or Checkr as applicable, may present separate privacy notices, biometric notices, consents, authorizations, or terms that govern the provider's direct collection, analysis, use, retention, disclosure, and deletion of BRI and Identity Review Information, which Applicants should review. In the event additional parties need access to BRI or Identity Review Information for technical support, administration, identity review, or other lawful purposes, West Monroe will provide such access only in accordance with applicable law.

Retention and Destruction of BRI

West Monroe does not intend to receive or store biometric data, biometric information, or biometric identifiers, as defined under applicable law (including the Illinois Biometric Information Privacy Act), in connection with the identity review process. Identity review is conducted by third-party providers such as CLEAR and Checkr, which collect and process biometric information directly and are subject to their own privacy notices, biometric notices, and terms. Accordingly, all retention and destruction commitments applicable to West Monroe under this section apply only to the extent West Monroe receives or possesses any BRI in connection with the identity review process.

To the extent West Monroe receives or possesses any BRI, West Monroe will retain such BRI only for as long as needed to satisfy the purpose for which such BRI was collected, stored, or used, subject to applicable law, legal process, litigation holds, regulatory obligations, background check requirements, audit requirements, or other lawful retention needs. To the extent West Monroe receives or possesses any BRI, West Monroe will permanently destroy such BRI as soon as practicable after the initial purpose for collecting or obtaining such BRI has been satisfied. West Monroe will retain Identity Review Information that is not BRI in accordance with its applicable records retention schedules and its applicant privacy notice, and only for as long as reasonably necessary for the purposes described in this Notice.

To the extent West Monroe receives or possesses any BRI qualifying as biometric data, biometric information, or biometric identifiers, West Monroe will not retain such BRI longer than three years after the Applicant's last interaction with West Monroe unless otherwise permitted or required by law, legal process, court order, warrant, subpoena, litigation hold, or other lawful retention obligation.

Identity review providers maintain their own retention and destruction schedules for BRI and related records.

Those schedules are governed by each provider's own legal obligations, contractual obligations to West Monroe, and the provider's applicable privacy notices, biometric notices, consents, authorizations, and terms. Please review the notices presented to you by those providers for information about their retention practices.

To the extent West Monroe receives or possesses any BRI in connection with the identity review process, West Monroe will require identity review providers by written contract to apply a retention and destruction schedule for BRI that is consistent with this Notice and to certify destruction on request.

Safeguarding BRI

West Monroe shall safeguard BRI in its possession or control, regardless of format, from unauthorized access, acquisition, or disclosure. Such safeguards shall include but not be limited to:

• Limiting access to BRI and related verification result information to Company personnel and service providers with a need to know.
• Maintaining reasonable administrative, technical, and contractual safeguards for BRI and related verification result information, including role-based access controls and vendor data protection obligations.
• Investigating and responding to a breach of BRI in accordance with West Monroe’s incident response plan and policy, and requiring service providers to support security incident response as required by contract and applicable law.

West Monroe shall use a reasonable standard of care to store, transmit, and protect from disclosure any BRI possessed. Such storage, transmission, and protection from disclosure shall be performed in a manner that is the same as or more protective than the manner in which West Monroe stores, transmits, and protects from disclosure other confidential and sensitive information, including, to the extent West Monroe ever possesses such data, personal information that can be used to uniquely identify an individual or an individual’s account or property, such as genetic markers, genetic testing information, account numbers, PINs, driver’s license numbers and social security numbers.

Accommodations

An Applicant who needs an accommodation because of a disability, a religious belief or practice, or another protected reason, may contact Talent Acquisition at [email protected] to request an alternative method of verifying identity. West Monroe will not retaliate against an Applicant for requesting an accommodation.

Contact, Questions, and Updates

Applicants may contact Talent Acquisition at [email protected] with questions about this Notice, to request a copy of this Notice or the Release, or to exercise rights available under applicable law. This Notice should be read together with West Monroe’s privacy policy, its Supplemental IDV Tools Notice for Job Candidates, and any background check disclosures provided separately. West Monroe may update this Notice, and the effective date above shows when this Notice was last updated.