Clawback Listing StandardsPublic companies should be aware that proposed NYSE and Nasdaq clawback listing standards may be in place earlier than expected. Organizations may use biometric data in a variety of ways, including when:tracking employee time; restricting access to physical and digital assets; monitoring consumer shopping behavior; and integrating biometric data into consumer products and services. Consider whether the organization’s current policies and procedures meet applicable biometric data handling requirements, including notice, consent, retention, storage, and security obligations. Review applicable laws and obligations when contracting with service providers that handle biometric data and continuously monitor their performance. In February 2023, the NYSE and Nasdaq filed proposed new listing standards, which contemplated that they could become effective as early as April 27, 2023.

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