Employee Privacy Policy
Table of Contents
- Categories of Personal Information We Collect
- Sources of Personal Information
- Purposes for Collecting or Disclosing Personal Information
- Disclosure of Personal Information
- Categories of Personal Information Sold or Shared
- California Privacy Rights
- How to Submit a Request
- Personal Information of Children Under the Age of 16
- Retention
- Changes to this Policy
- Questions
This Employee Privacy Policy (“Policy”) is adopted by Wawanesa General Insurance Company (“Wawanesa”, “we” or “us”) to comply with the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”) and applies solely to residents of the State of California who are employees, job applicants, and independent contractors of Wawanesa (collectively, “you” or “employees”). This Policy describes how we collect, use, and disclose personal information about you, including sensitive personal information, as such terms are defined in the CCPA. This Policy applies to personal information collected about you in your capacity as an employee. See our Privacy Policy for information about our practices when you interact with us offline or online in the same manner that a website visitor or other non-employee may interact with us.
For the purposes of this Policy, personal information does not include publicly available information such as information from government records or information made available to the general public or de-identified or aggregated information.
1. Categories of Personal Information We Collect
We have collected the following categories of personal information in the preceding 12 months:
| Category of Personal Information Collected | Examples | Disclosed for a Business Purpose |
|---|---|---|
| Category of Personal Information Collected Identifiers | Examples Name, postal address, email address, date of birth, telephone number, Social Security Number, driver’s license number or state identification card number, bank account information if using direct deposit, or other similar identifiers | Disclosed for a Business Purpose YES |
| Category of Personal Information Collected Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | Examples Name, signature, physical characteristics or description, address, telephone number, bank account number if using direct deposit, health insurance information, driver’s license number or state identification card number, education, or employment history | Disclosed for a Business Purpose YES |
| Category of Personal Information Collected Protected classification characteristics under California or federal law | Examples Age, race, color, ancestry, national origin, citizenship or immigration status, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identify, gender expression), same sex orientation for same sex benefits, veteran or military status | Disclosed for a Business Purpose YES |
| Category of Personal Information Collected Biometric Information | Examples Fingerprint or facial recognition | Disclosed for a Business Purpose YES |
| Category of Personal Information Collected Internet or Network Activity | Examples Browser history, search history, IP address, mobile device identifier, cookies, use of IT resources, and interaction with websites, keycard scans, information about your access to and location within offices and facilities (e.g., keycard scans and security scans and security camera footage) | Disclosed for a Business Purpose YES |
| Category of Personal Information Collected Geolocation data | Examples Physical location, keycard scans | Disclosed for a Business Purpose YES |
| Category of Personal Information Collected Audio, electronic, or visual data | Examples Audio recordings, pictures, and videos | Disclosed for a Business Purpose YES |
| Category of Personal Information Collected Professional or employment-related information | Examples Current or past job history or performance evaluations | Disclosed for a Business Purpose YES |
| Category of Personal Information Collected Inferences drawn from other personal information | Examples Profile reflecting a person's preferences, characteristics, behavior, attitudes, intelligence, abilities, and aptitudes | Disclosed for a Business Purpose YES |
| Category of Personal Information Collected Sensitive Personal Information | Examples Social Security Number, driver’s license, state identification card, racial or ethnic origin, health data, fingerprint and facial recognition, or sexual orientation | Disclosed for a Business Purpose YES |
2. Sources of Personal Information
We collect personal information from you during your candidacy for a job, and during and after your employment. We also collect personal information from various other sources and combine it with the personal information you provide to us. We collect personal information from the following sources:
- Job board websites you may use to apply for a job with us;
- Government entities;
- Providers of services that we make available to our employees as part of our benefits programs;
- Payroll providers;
- Prior employers, when they provide us with employment references;
- Educational institutions;
- Professional references that you authorize us to contact;
- Background check and screening providers;
- Employment agencies and recruiters; and
- Any other lawful sources.
3. Purposes for Collecting or Disclosing Personal Information
We collect and disclose personal information for one or more of the following purposes:
- To establish and maintain communication with you;
- To evaluate qualifications for employment;
- To administer payroll and employment benefits;
- To manage workers’ compensation claims;
- To arrange and manage Wawanesa sponsored events;
- To establish training and development requirements;
- To manage your job-related performance;
- To develop, implement and evaluate diversity equity and inclusion initiatives;
- For recordkeeping purposes;
- To administer payments and reimburse for expenses;
- To investigate and handle disciplinary actions and terminations;
- For research analysis, and business development, including to develop and improve Wawanesa business processes and services;
- To facilitate or complete an actual or prospective business transaction, including, but not limited to, investments in Wawanesa, financing of Wawanesa, or the sale, transfer or merger of all or part of our business, assets, or shares;
- To develop, maintain, and improve our website and other online programs and services relating to your employment or potential employment;
- To protect the safety and security of Wawanesa’s employees and to maintain the security and integrity of our systems, our assets and our facilities;
- To comply with laws and regulations, including, but not limited to, applicable tax, health and safety, immigration and labor and employment laws;
- To respond to requests from law enforcement, government or regulatory authorities, law enforcement or court order;
- To monitory, investigate and enforce Wawanesa policies and procedures and legal and regulatory requirements;
- To establish or defend legal rights, claims and allegations;
- For security and the prevention, detection, or investigation of fraud, suspected or actual illegal activity, or other misconduct:
- To grant and monitor your access to company systems and facilities; and
- For any other lawful purpose.
4. Disclosure of Personal Information
We have disclosed personal information to the following categories of third parties in the preceding 12 months:
- Our parent company;
- Providers of services to Wawanesa, including, but not limited to payroll, benefits and wellness programs, performance management, and background checks;
- Government authorities, regulatory agencies and law enforcement;
- Accountants, auditors, lawyers, insurers, and other professional advisors;
- Third parties to facilitate or complete an actual or prospective business transaction, including, but not limited to, investments, financing or the sale, transfer or merger of all or part of the company;
- Other parties not listed above that are identified at or before the point at which we collect personal information along with the purposes for which the information will be shared.
5. Categories of Personal Information Sold or Shared
Wawanesa has not sold or shared personal information with any third parties in the preceding 12 months.
6. California Privacy Rights
The CCPA provides California employees with certain rights regarding their personal information. However, these rights are not absolute and are subject to certain exceptions. This Section explains those rights.
A. Right to Know About Your Personal Information
You have the right to request that Wawanesa provide you with information regarding the personal information Wawanesa has collected about you in the preceding twelve (12) months. Once we receive your request and verify your identity, we will disclose to you, subject to any exemptions under the CCPA, the following:
- Categories of personal information collected;
- Categories of sources from which the personal information is collected;
- Business or commercial purpose for collecting, selling, or sharing the personal information;
- Categories of third parties to whom Wawanesa disclosed the personal information; and
- Specific pieces of personal information Wawanesa has collected about the consumer.
In addition to the CCPA rights discussed above, California law provides current and former employees with the right to request certain information relating to their employment, such as the right to access their personnel file and payroll records. Because these requests are governed by laws that contain different requirements than the CCPA, we handle such requests separately from CCPA requests. If you would like to make such a request, please submit your request to SD_human_resources@wawanesa.com.
B. Right to Delete Your Personal Information
You have the right to request that Wawanesa delete your personal information that we have collected from you. However, this right to does not apply to any personal information exempt under the CCPA. Once we receive your request and verify your identity, we will delete any personal information in our records that is not subject to any of the CCPA exemptions.
C. Right to Correct
You have the right to request that Wawanesa correct any inaccurate personal information that Wawanesa has about you. Once we receive your request and verify your identify, we will correct any inaccurate personal information that we have collected about you.
Note: Current employees can update or correct personal information in PCR by going to “View My Profile” and clicking on the pencil icon next to each section heading.
D. Right to Limit the Use and Disclosure of Sensitive Personal Information
You have the right to limit the use and disclosure of your sensitive personal information. However, we do not use or disclose sensitive personal information in ways subject to the right of California residents to limit use of sensitive personal information under the CCPA. If we change our practices in the future, we will notify you by updating this Privacy Policy.
E. Right to Opt-Out of the Selling or Sharing of Personal Information
You have the right to direct a business that sells or shares personal information to third parties to not sell or share your personal information. However, we do not and have not in the preceding 12 months, sold or shared (in this context, share means use of your Personal Information for cross-contextual behavioral advertising) your personal information.
F. Right to Non-Discrimination
You have the right to not receive discriminatory treatment and not be retaliated against for exercising your CCPA rights.
7. How To Submit a Request
If you would like to exercise your CCPA rights identified above, you may submit a request here and or by calling us at 800-640-2920 and selecting Option 7.
A. How We Verify Your Identity and Requests
To process your request, we must be able to verify your identity or authority to make the request and confirm the personal information relates to you. This requires that you submit all requests here or by calling us at 800-640-2920 and selecting Option7. When submitting your request, you must provide your full name, your relationship to Wawanesa, employee ID if you are a current Wawanesa employee, your address, your email address, and phone number, and any other information pertaining to your request. Submitting your request through one of these channels allows us to verify your identity as required by the CCPA. As such, we cannot accept requests though other channels. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. We reserve the right to confirm your current California residency.
Note: You can find your employee ID on Dayforce under your “Profile.” Depending on the type of request or the information requested by you, we may require additional information to verify your identify and fulfill your request. If we cannot successfully verify your identity, we will inform you of that fact.
B. Responding to Your Requests
We will respond to your request within forty-five (45) days. However, in certain circumstances, we may require additional time to process your request, as permitted by the CCPA. We will advise you within forty-five (45) days after receiving your request if an extension is necessary and why it is needed. If we cannot fulfill your request, our response to you will explain the reason why.
C. Submitting a Request Through Your Authorized Agent
You have the option to designate an authorized agent to submit a request on your behalf. We may require you and your authorized agent to verify your identify or confirm that the agent has permission to submit a request on your behalf.
8. Personal Information of Children Under the Age of 16
Wawanesa does not seek to, nor do we knowingly collect, information directly from children under the age of 16. As we do not sell or share any personal information, we also have not sold or shared the personal information of children under the age of 16.
9. Retention
We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for the compliance and protection purposes identified above.
10. Changes to this Policy
We reserve the right to change this Policy at any time. The “Effective Date” listed at the bottom of this Policy indicates when it was last revised. All updated notices will be posted on the Policy Library and our website.
11. Questions
If you have any questions about this Policy, you may contact us at:
By Mail:Wawanesa General Insurance Company
Attention: Legal Department
PO Box 82867
San Diego, CA 92138-9492
By E-mail:
uslegal@wawanesa.com
The Effective Date and the date of the last update of this Policy is April 26, 2024.