(Version 1.0 | Rev 06/12/2020)
1. PURPOSE AND INTENT
This policy applies to applicants, current and former employees and their emergency contacts and beneficiaries, and independent contractors. This policy does not form part of any contract of employment or other contract to provide services. We may update this policy at any time.
2. DATA PROTECTION PRINCIPLES
We will comply with applicable data protection law. This says that the personal information we hold about you must be: (i) used lawfully, fairly and in a transparent way; (ii) collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes; (iii) relevant to the purposes we have told you about and limited only to those purposes; (iv) accurate and kept up to date; (v) kept only as long as necessary for the purposes we have told you about; and (vi) kept securely.
3. WHAT PERSONAL INFORMATION IS COLLECTED AND HOW IT IS USED
For job applicants, please refer to the Company’s PRIVACY NOTICE TO CALIFORNIA JOB APPLICANTS REGARDING THE COLLECTION OF PERSONAL INFORMATION for what information we collect about job applicants and how we use and disclose it.
For employees and former employees and their emergency contacts and beneficiaries, please refer to the Company’s PRIVACY NOTICE TO CALIFORNIA EMPLOYEES, EMERGENCY CONTACTS AND BENEFICIARIES REGARDING THE COLLECTION OF PERSONAL INFORMATION for what information we collect about employees and former employees and how we use and disclose it.
For independent contractors that we engage, please refer to the Company’s PRIVACY NOTICE TO CALIFORNIA INDEPENDENT CONTRACTORS REGARDING THE COLLECTION OF PERSONAL INFORMATION.
The Company does not sell or otherwise disclose your personal information for monetary consideration or a business purpose to any third parties. The Company may share your personal information to trusted service providers who process personal information on our behalf to achieve our business purposes.
4. FAILURE TO PROVIDE PERSONAL INFORMATION
If you fail to provide certain information when requested, we may not be able to address our employment or contract obligations (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
5. CHANGE OF PURPOSE
We will only use your personal information for the purposes we have disclosed in our notice(s). If we need to use your personal information for an unrelated purpose, we will notify you. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. DATA SECURITY
While no data security system can fully protect personal information from unauthorized data breaches, the Company has implemented reasonable safeguards and controls, consistent with its legal obligations under CA and other local, state and federal laws. The Company is committed to: (i) seeking to safeguard all personal information that you provide to us; (ii) seeking to ensure that it remains confidential and secure; and (iii) taking all reasonable steps to ensure that personal privacy is respected. All our data is stored in written or electronic form on our servers and computers and in various physical locations. We maintain physical, electronic and procedural safeguards to protect your personal information from misuse, unauthorized access or disclosure and loss or corruption by computer viruses and other sources of harm. We restrict access to personal information to those staff members, The Company and third parties who need to know that information for the purposes identified in our notice(s).
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
7. DATA RETENTION
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Once you are no longer an employee or contractor of the Company, we will retain and securely destroy your personal information in accordance with the Company’s record retention policies.