DHCR Permits Switch from Key Locks to Electronic Key Cards

Landlord of three interconnecting buildings asked the DHCR for permission to replace the key locks on all entry doors, including the doors to the laundry rooms and the garage, with an electronic card access entry system by which tenants would use a keyless electronic card instead of a metal key to access the doors. The DRA approved the service modification on a number of conditions, including that: (1) a CCTV system would be installed to verify the identity of the person entering using the key card; (2) security services would be in place 24 hours a day, seven days a week to assist tenants who are locked out; (3) religious observers who could not use electronic devices on the Sabbath would be able to use a side entrance door opened by building staff; and (4) tenants would receive up to four cards free of charge and be charged $15 for additional cards.
Tenants appealed and lost. They claimed that it was an invasion of privacy to require their photos on key cards, and that their photos and other data to be stored by landlord in connection with the new system could be misused. But the DHCR found that the tenants' photos were a crucial security measure and that the data to be provided by tenants was data landlord already had or was entitled to.

120 West 97th Street: DHCR Adm. Rev. Docket Nos. XH410021RT, XH410043RT, XH410044RT (7/6/11) [5-pg. doc.]