Landlord Met Conditions for Replacing Traditional Key-Lock with Electronic Key Fob System

Landlord asked the DHCR for permission to replace the main entrance door's metal keys with an electronic key fob system. The DRA ruled for landlord and listed 13 conditions that landlord must comply with concerning the service modification. Tenants appealed and lost. They objected to the requirement that persons receiving a key fob sit for a photo to be electronically associated with the key fob in the security system database. But this requirement was consistent with DHCR policy and was an appropriate security measure. The requirement that persons obtaining a key fob/keycard provide proof of identity to the landlord also was consistent with DHCR policy and building security. The DHCR provided that minors weren't required to sit for photos and prohibited landlord from recording any data when a tenant provided proof of identity. Finally, replacement of a traditional key-lock system with a key fob or keycard entry system didn't violate the rent laws or privacy rights. 

Various Tenants: DHCR Adm. Rev. Docket No. FT410055RT (8/14/19) [2-pg. doc.]