Employee and Applicant Privacy Policy

I. What Personal Information Means

Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household. It does not include publicly available information or lawfully obtained, truthful information that is a matter of public concern. Personal Information does not include aggregated or deidentified information.

Some Personal Information is defined as Sensitive Personal Information under California law. The Company does not collect or process Sensitive Personal Information to infer characteristics about applicants or employees.

II. Categories of Personal Information the Company Collects

The Company collects the following categories of Personal Information about employees and job applicants and has done so within the 12 months since this Policy was last updated:

• Identifiers (such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)
• Personal information described in the California Customer Records Law (such as name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or other financial information, medical information, or health insurance information)
• Characteristics of protected classifications under California or federal law (such as race, national origin, religion, sex, gender, sexual orientation, disability, and age)
• Commercial information (such as records of personal property, products, or services purchased)
• Internet or other electronic network activity information (such as browsing history and search history)
• Geolocation data
• Audio and visual information
• Professional and employment-related information
• Education information subject to the federal Family Educational Rights and Privacy Act (such as student transcripts)
• Inferences (drawn from any of the categories of information listed above to create a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes)

III. Where the Company Collects Personal Information From

The Company collects Personal Information about employees and job applicants from the following sources:

• The employee or applicant
• The employee or applicant (via the Company’s human resources service providers)
• The applicant’s references
• Prior employers
• The Company’s internet content filtering and identity protection service providers
• Security systems at the Company’s office locations
• Online behavioral self-assessment tools (based on employee self-assessments)

IV. Why the Company Collects Personal Information

The Company collects Personal Information about employees and job applicants for the following reasons:

• To communicate with the employee or applicant
• To administer the recruiting and employment application processes
• To administer the employment relationship, including providing human resources services, employee training and evaluation, and employee benefits
• To verify work eligibility
• To administer payroll and reimbursements
• To report affirmative action data
• To market the Company’s employees to clients
• To verify eligibility for clients’ small, minority, or other disadvantaged business enterprise classifications
• To administer information technology services, including IT security
• To maintain security at the Company’s office locations
• To comply with federal, state, or local laws
• To cooperate with law enforcement agencies concerning conduct or activity that the Company reasonably and in good faith believes may violate federal, state, or local law.

V. Who the Company Discloses Personal Information to

The Company discloses Personal Information about employees and job applicants to the following categories of third parties:

• Service providers that provide the Company with recruiting and employment application support services and administration
• Service providers that provide the Company with human resources support services and administration
• Service providers that provide the Company with employment benefits support services and administration
• Service providers that provide the Company with payroll support services and administration
• Service providers that provide the Company with accounting support services and administration
• Service providers that provide the Company with information technology support services and administration

If needed, the Company may also disclose Personal Information about employees and job applicants to the following categories of third parties:

• The Company’s insurance companies to make insurance claims or perform investigations
• The Company’s legal counsel to exercise or defend actual or potential legal claims or perform investigations
• Federal, state, and/or local agencies to comply with applicable laws or to comply or cooperate with an investigation
• Other third parties to comply with a court order or subpoena or to exercise or defend actual or potential legal claims

VI. How Long the Company Retains Personal Information

The Company retains most Personal Information about employees during the length of employment plus 4 years. The Company retains most information about job applicants for 4 years from creation. The criteria the Company uses to determine retention periods includes the length of time the Company has an ongoing relationship with the applicant or employee, the Company’s obligations under applicable law, and the potential for claims, litigation, investigations, or other legal or regulatory issues. Employees may find the Company’s Records Retention and Destruction Policy on the Hub.

VII. The Company Does Not Sell Personal Information or Share it With Advertisers

The Company does not sell Personal Information of job applicants or employees and has not done so in the preceding 12 months. The Company does not share Personal Information of job applicants or employees with advertisers and has not done so in the preceding 12 months.

VIII. Privacy Rights

All job applicants and employees have the following privacy rights:

• The Right to Know: Applicants and employees have the right to request that the Company disclose the following to that applicant or employee:
  • • The categories of Personal Information the Company has collected about that applicant or employee
    • The categories of sources from which the Personal Information is collected
    • The purpose for collecting, selling, or sharing the Personal Information
    • The categories of third parties to whom the Company discloses Personal Information
    • The specific pieces of Personal Information the Company has collected about that applicant or employee
• The Right to Delete: Applicants and employees have the right to request that the Company delete any Personal Information about the applicant or employee that the Company has collected from that applicant or employee.
• The Right to Correct: Applicants and employees have the right to request that the Company correct any inaccurate Personal Information the Company maintains about that applicant or employee.
• The Right to Non-Discrimination: The Company will not discriminate against an applicant or employee because that applicant or employee exercised the right to know, delete, or correct under this Privacy Policy.

To exercise the right to know, delete, and/or correct Private Information, please contact Corporate Human Resources, email privacy@fehrandpeers.com, or send a request by mail to:

Fehr & Peers
100 Pringle Avenue, Suite 600
Walnut Creek, CA 94596