Privacy Notice for California Employees and Contractors

Effective: 2024 January 1

This Privacy Notice (“Privacy Notice” or “Notice”) explains how Westfield insurance companies (“we,” or “us,” or “our”) collects personal information about our California employees and contractors (“employment personal information”), to the extent such personal information is collected and used by us solely within the context of their role or former role as our employee or contractor.

Notice at Collection: Personal Information We Collect

We collect the following categories of employment personal information:

• Personal identifiers: name, contact details (for you, your emergency contacts), identifying information of beneficiaries, IP address, social security number, driver’s license information or passport information, account, and password information for applications we use, badge ID information
• Protected class information: race, ethnicity, and other diversity data; gender identity or expression; marital status; age; national origin; religion; requests for family care, medical or parental leave; disability status, veteran status
• Financial information: bank account information to deposit paychecks or bonus payments, compensation amounts, social security premiums (including amounts paid, the frequency and currency of payments), benefits information (e.g., health insurance, 401k contributions) (including amounts paid, the frequency and currency of payments), credit card and frequent flyer account information
• Internet or other electronic activity information: information we obtain through your interaction with company-owned devices or on our network, including your location when using VPN or using mobile devices owned by the company
• Professional information: records of your work and education history (including internal and external work history and references); records of your performance (including evaluations and ratings, grievances, and disciplinary records); records regarding your work location, job title and seniority); and information relating to absences from work
• Educational information: Education history; trade school records; certificates obtained
• Audio or visual information: recordings made of videoconference calls; recordings of calls made to Westfield call centers or help lines; video promotional materials
• Inferences drawn from the above categories of personal information
• Sensitive personal information: Social security number, driver’s license information or passport information; race, ethnicity, and other diversity data; religion; personal information regarding health (e.g., requests for family care, medical or parental leave; disability status); personal information concerning sexual orientation

We have collected the same categories of employment personal information in the 12 months prior to the date of this Privacy Notice.

Notice at Collection: Purposes for Collection of Personal Information

We use employment personal information to undertake the following:

• administer human resources functions such as performance reviews and appraisals, sick leave, training, internal organizational charts, internal communications, and termination or retirement issues;
• administer payroll, benefits, insurance, and other benefits-related functions;
• manage personnel communications including authorizing, granting, and administering access to or use of our systems, facilities, devices and records;
• analyze employee performance and compensation levels;
• investigate and resolve complaints, grievances or misconduct;
• prepare for and act in relation to inquiries, investigations, or proceedings, by governmental, administrative, judicial, or regulatory authorities, including civil litigation;
• maintain network and system security and address access-related issues, including by protecting the Company by monitoring internet access and use and emails transmitted;
• implement health and safety protections;
• defend legal claims; and
• effect any other purposes related to carrying out our business.

 

Notice at Collection: Categories of Personal Information We Sell or Share

We do not sell or share for cross-context behavioral advertising employment personal information.

Notice at Collection: Retention Periods

We retain the categories of employment personal information for the length of time necessary to operate our business, comply with legal obligations and to protect our legal rights.

Sources From Which We Collect Personal Information

We collect employment personal information directly from employees, from other employees or contractors, from benefits providers, through our internal IT systems and/or Company-issued mobile devices, from Company-owned vehicle monitoring systems, and from internal systems that may monitor employees or independent contractors.

Use or Disclosure of Sensitive Personal Information

We do not use or disclose sensitive employment personal information to infer characteristics about employees or contractors or for any purposes other than to operate our business.

Disclosure of Personal Information For Business Purposes in the Past 12 Months

The following chart describes the categories of employment personal information that we disclosed to third parties for a business purpose in the 12 months prior to the date of this Notice:

Business Purposes for Such Disclosures

We disclosed the aforementioned categories of employment personal information to the categories of third parties identified above for the following purposes: to provide human resource functions; provide and administer benefits; facilitate scheduling and email communications; provide security services and cloud-based data storage, assist with other IT-related functions; provide employee and compensation analytics; host or facilitate teleconferencing or video conferencing; prevent fraud and other illegal activities; and to obtain professional advice about legal and accounting matters.

Additional Information About How We May Disclose Employment Personal Information

We may also share employment personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property, or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also share applicant personal information with third parties to help detect and protect against fraud or data security vulnerabilities. And we may share or transfer applicant personal information to a third party in the event of an actual or potential sale, merger, reorganization of our entity or other restructuring.

Rights Related to Personal Information Held by Us

Your Right To Know About Personal Information We Collect

You can ask us for the following information from us with respect to the employment personal information that we have collected about you in the 12 months prior to the date of your request:

• Specific pieces of personal information we have collected about you;
• Categories of personal information we have collected about you;
• Categories of sources from which such personal information was collected;
• Categories of personal information that the business sold or disclosed for a business purpose about you;
• Categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
• The business or commercial purpose for collecting or selling your personal information.

 

Your Right To Request Deletion of Personal Information We Have Collected From You

Upon your request and subject to exceptions in the law, we will delete employment personal information we have collected about you.

Your Right to Request to Correct Personal Information We Hold About You

You have the right to request that we correct personal information we hold that you believe is not accurate. We will take steps to determine the accuracy of the personal information that is the subject of your request to correct, and in doing so will consider the totality of the circumstances relating to the personal information you have identified as being incorrect. We may ask that you provide documentation regarding your request to correct in order to assist us in evaluating the request.

Our Commitment to Honoring Your Rights

If you exercise any of the rights explained in this Privacy Notice, we will continue to treat you fairly.

Exercising Your Rights and How We Will Respond

To exercise your rights to know, delete, or correct applicant personal information, or to ask a question about your data subject rights, contact us at 1-800-243-0249 or click here. For such requests, will first acknowledge receipt of your request within 10 business days of receipt of your request. We will then provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances.

We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations.

In some cases, the law may allow us to refuse to act on certain requests.

Verification of Identity

If you submit a request, we will ask you for two pieces of personal information and attempt to match those to information that we maintain about you.

If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial.

Authorized Agents

You may designate an agent to submit requests on your behalf. The agent can be a natural person or an entity.

If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our verification process. Specifically, if the agent submits requests to access, know or delete your personal information, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the request on your behalf. We will also require that you verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request.

Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.

Personal Information of Minors

We do not employ or contract with minors under the age of 16 and do not knowingly collect or sell the personal information of such minors.

How We Keep Your Personal Information Secure

We maintain reasonable security measures appropriate to the nature of the personal information that we collect, use, retain, transfer or otherwise process. Those measures include administrative, technical, and physical safeguards designed to protect the personal information you provide against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. However, data security incidents and breaches can occur due to a variety of factors that cannot reasonably be prevented; therefore, our safeguards may not always be adequate to prevent all breaches of security.

Changes to This Notice

We may update this notice from time to time. When we make substantive changes, we will update date of this Notice. In certain cases and if the changes are material, you will be notified via email or a notice on our website.

Accessibility

We work to make our communications accessible to people with disabilities. To submit accessibility-related requests or report barriers, please contact HR at 1-800-552-9139.

Contact Us

If there are any questions regarding this Privacy Notice or to request a copy of this Privacy Notice in another format you may contact us at 1-800-243-0249.