NABP Biometric Information Policy

Last Updated: April 21, 2020

The National Association of Boards of Pharmacy^® (NABP^®) owns, develops, and administers various examinations, including the North American Pharmacist Licensure Examination^® (NAPLEX^®), the Multistate Pharmacy Jurisprudence Examination^® (MPJE^®), and Foreign Pharmacy Graduate Equivalency Examination^®. Boards of pharmacy of the United States use two or more of these examinations to determine if a candidate has met the educational requirements for pharmacist licensure. Because an individual may attempt to engage in fraud on one or more of NABP’s examinations, the Association takes significant steps to help ensure the security and integrity of its examinations.

A key NABP security measure addresses accurately identifying examination candidates to help detect and prevent examination fraud across Association exams. Examination fraud includes, without limitation, individuals who take, or attempt to take, an examination for another individual or who take an examination without NABP or board of pharmacy authorization (for example, to access or memorize test questions for disclosure or sale to others). Palm vein scanning technology is used by NABP and the NABP test administration vendor, Pearson VUE and its contractors, as one method to deter and detect examination fraud. The purpose of this policy is to comply with applicable law and inform NABP examination candidates how palm vein scans are collected, retained, and permanently destroyed in accordance with applicable law.

Notice & Consent

NABP provides information about the collection of palm vein scans in its candidate application bulletins for NABP examinations and in this policy. When candidates arrive at the Pearson VUE testing center to check-in for an NABP examination, they are provided with information about the collection of palm vein scanning and are asked to read and sign an agreement consenting to the collection of their palm vein scan.

Collection

After candidates sign the consent agreement, the examination check-in process at the Pearson VUE testing center includes the collection of candidates’ palm vein scans. Candidates place their hand on a device containing a sensor with palm vein technology. This device scans veins in each candidate’s palm using a safe near-infrared light source like that in a television remote control. Each time a candidate takes a break from the examination, their palm is scanned when returning to the testing room and the results are compared to the candidate’s original scan to verify their identity. When a candidate takes an NABP examination at a later date, one or more palm vein scans are collected from the individual and are subject to comparison with the original scan and other candidate palm vein scans. After a candidate finishes taking an NABP examination, the test results and palm vein scans are sent to Pearson VUE via encrypted transmission, are securely stored, and palm vein scans are disposed of as described in this policy.

Purpose and Use

The purpose for collecting an individual’s palm vein scan is to detect and prevent fraud in connection with NABP examinations. An initial palm vein scan is collected by Pearson VUE to create a template for that individual and compare it to one or more palm vein scans that are collected 1) during the same testing session (eg, when an individual returns to the testing room after a break) and 2) when administering subsequent examinations (eg, an individual who re-takes an examination after previously failing, or an individual who passed the NAPLEX and who later takes the MPJE test as may be required for pharmacist licensure). NABP may perform comparisons among a candidate’s palm vein scans that are collected after the original scan or may compare a candidate’s palm vein scans to those of other candidates to identify individuals who may have tested under multiple names or identities. NABP may use palm vein scans to protect or defend NABP’s rights, property, staff, or members, or the rights, property, or safety of others to the greatest extent permitted under applicable law.

Retention and Destruction

Palm vein scans and information based on or derived from the scans are retained for three years after the candidate successfully passes the FPGEE, NAPLEX, or MPJE examination or three years after the candidate’s last interaction with NABP, whichever occurs first, unless otherwise required or permitted by law. Palm vein scans and information based upon or derived from the scans are permanently destroyed following expiration of the applicable retention period described in this policy.

Disclosure

Pearson VUE, its contractors, and NABP do not sell, lease, trade, or profit from palm vein scans or information based on or derived from these scans.

Pearson VUE, its contractors, and NABP do not disclose, redisclose, or disseminate palm vein scans or information based on or derived from these scans unless an individual consents to disclosure or redisclosure; disclosure or redisclosure is required by state or federal law or municipal ordinance; or disclosure or redisclosure is required by valid warrant or subpoena issued by a court of competent jurisdiction.

Storage and Transmission

Pearson VUE and/or its contractors store, transmit, and protect from disclosure palm vein scans and related data using a reasonable standard of care within the industry, but in no event in a manner that is less protective than how Pearson VUE or its contractors store, transmit, or protect from disclosure its other confidential or sensitive information.

NABP does not receive, store, or transmit palm vein scans or related data except if there is an issue or concern about candidate-involved examination fraud as described in this policy. If such an issue or concern arises, NABP may receive, store, or transmit palm vein scans or related data, in which case NABP will protect the scans and related data from disclosure using a reasonable standard of care within the industry, but in no event in a manner that is less protective than how NABP stores, transmits, or protects from disclosure its other confidential or sensitive information.

Policy Statement

NABP may revise this policy from time to time. If any provision of this policy is held unlawful, void, or for any reason unenforceable, then that provision shall be deemed severable from this policy and shall not affect the validity and enforceability of any remaining provisions. Headings included in this policy are for reference purposes only.