This Privacy Policy explains how personal data is processed in the Attendance Muster platform — the web portal and mobile apps used by organisations to manage employee attendance, leave and time.

On this page
  1. Our role and yours
  2. Legal basis
  3. Information we process
  4. How we use it
  5. Facial images and biometrics
  6. Location data
  7. Sharing and sub-processors
  8. Security and data residency
  9. Retention
  10. Your rights
  11. Contact and grievances

1. Our role and yours

The Attendance Muster platform is provided by Calibehr Business Support Services Pvt. Ltd. ("Calibehr", "we", "us"). Your employer or organisation — the tenant that deployed the platform for you — is the Data Fiduciary that decides why and how your data is processed. Calibehr acts as a Data Processor on your organisation's instructions and provides the technology, hosting and security controls described here. Where this policy and your organisation's own privacy notice differ, your organisation's notice governs your employment relationship.

2. Legal basis

The platform processes personal data under the Digital Personal Data Protection Act, 2023 (DPDP Act). Attendance, leave and workforce data are processed on the basis of legitimate use for the purposes of employment under Section 7 of the DPDP Act — not on the basis of consent. You are given a clear Notice of processing; the platform does not ask you to "consent" to attendance capture, because it is a legitimate, employment-related purpose.

3. Information we process

Depending on how your organisation configures the platform, we process:

  • Identity and employment data — name, employee code, work email, designation, department, branch, shift, manager and reporting structure.
  • Attendance events — clock IN/OUT times, attribution dates, worked and late minutes, leave, holidays and regularisation requests.
  • Facial images and biometric verification data — the photo captured at clock-in and the biometric templates/reference identifiers used to verify it is you (see section 5).
  • Location data — the latitude/longitude at clock-in, geo-fence boundary events and significant-location-change signals during a shift (see section 6).
  • Device and integrity signals — device model/OS, app version, and safety checks (e.g. mock-location, rooted/jailbroken or emulator detection) used to prevent fraud.
  • Account and security data — hashed password, multi-factor authentication settings, sign-in events and audit logs.

4. How we use it

  • To record and verify attendance and working time, and to compute leave and related entitlements.
  • To confirm that attendance is marked by the correct employee, from a permitted location, on a genuine device — protecting the integrity of pay and workforce records.
  • To operate manager/HR workflows (approvals, regularisation, reporting) within your organisation.
  • To secure the service, detect and prevent fraud and misuse, and maintain audit trails.
  • To meet your organisation's legal, tax and compliance obligations.

We do not sell your personal data, and we do not use facial, biometric or location data for advertising or third-party analytics.

5. Facial images and biometrics

Where face verification is enabled, the mobile app performs an on-device quality pre-check, then the captured image is sent over an encrypted channel to be matched against your enrolled reference. Face matching and passive liveness detection run on Amazon Rekognition within the AWS Asia Pacific (Mumbai / Hyderabad) region — biometric data is not sent outside India.

  • Biometric templates and reference identifiers are treated as sensitive personal data and are encrypted at rest with per-tenant keys.
  • Face images are accessed only through short-lived, authenticated links — never emailed or shared in plain form, and never posted to any third-party analytics service.
  • Passive liveness only (no active challenges at launch); the platform checks that a live person is present, not your emotions or identity beyond the attendance match.

6. Location data

Location is used to confirm attendance is marked within a permitted branch geo-fence and, where your organisation enables it, to record significant-location-change signals during a shift. This is not continuous, real-time tracking: readings are periodic and purpose-limited. Precise coordinates are protected — where location appears in system logs it is truncated to reduce precision. Managers and HR may see last-known on-shift locations only where your organisation has enabled that feature, and such access is audit-logged.

7. Sharing and sub-processors

We share personal data only as needed to run the service:

  • Amazon Web Services (India regions) — hosting, storage and Rekognition face matching / liveness.
  • Push notification providers — Firebase Cloud Messaging (Android) and Apple Push Notification service (iOS), to deliver app notifications.
  • Email provider — to send transactional emails (e.g. account and password messages). The platform does not send SMS.

We may also disclose data where required by law or to protect the security and rights of users and the service. We do not share biometric or location data with advertisers or data brokers.

8. Security and data residency

The platform is designed to be ISO/IEC 27001:2022 aligned and data is hosted in India. Protections include encryption in transit (TLS) and at rest, per-tenant key management for sensitive fields, strict tenant isolation (row-level security so one organisation can never see another's data), passwords hashed with Argon2id, certificate pinning on the mobile apps, multi-factor authentication, and comprehensive audit logging of sensitive actions.

9. Retention

Personal data is retained for as long as needed for the purposes above and to meet your organisation's legal and record-keeping obligations, after which it is deleted or anonymised. Attendance photos and biometric verification data are kept only for a limited retention window and then erased. On offboarding (when you leave the organisation, or the organisation leaves the platform) data is exported to your organisation and then securely deleted according to the agreed schedule.

10. Your rights

Under the DPDP Act you have rights to access and to seek correction or erasure of your personal data, and to grievance redressal. Because attendance processing relies on the Section 7 legitimate-use basis (not consent), some rights are exercised through your employer as Data Fiduciary. Please raise requests through your organisation's HR or grievance channel; Calibehr will support your organisation in fulfilling valid requests. To request deletion of your account and data, see Delete your account.

11. Contact and grievances

For questions about this policy or to raise a grievance, contact your organisation's HR team, or reach Calibehr's privacy contact at automate@calibehr.com. Grievance Officer: Ramyash Yadav, automate@calibehr.com, Calibehr Business Support Services Pvt. Ltd., T-161, 6th Floor, Tower No. 10, ITC Park, CBD Belapur, Navi Mumbai, Maharashtra, India – 400 614.