California Employee Privacy Policy

Effective Date: 26 July 2023

Ennismore Holdings US Inc (collectively “Ennismore,” “we,” “our,” or “us”) respects the privacy of our employees’ personal information.

Pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”), we are required to provide California employees with a privacy policy that contains a comprehensive description of our online and offline practices regarding our collection, use, sale, sharing, and retention of their personal information as well as a description of the rights they have regarding their personal information. This Privacy Policy provides the information the CCPA requires as well as other useful information regarding our collection and use of personal information.

Please review this Privacy Policy carefully. From time to time, we may change this Privacy Policy. If we do, we will post an amended version on this webpage and on Workplace. You also may receive a copy by contacting us as described in the “How to Contact Us” section below.

This Privacy Policy covers the following topics:

Personal Information We Collect

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified, or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this Privacy Policy, we will refer to this information as “Personal Information.”

Below are the categories of Personal Information we currently collect and, in the 12 months prior to the Effective Date of this Privacy Policy, have collected from past, current, and potential employees. Please note that the Personal Information we collect depends on your position, relationship to us, what information you choose to provide, and what information we are required to collect. Not all Personal Information listed below is collected from all past, current, and potential employees.

• Identifiers (name; alias; account name; email address; postal address; Social Security number; driver’s license number; other types of state identification card numbers such as California ID Cards; passport number; IP address; online identifiers; other similar identifiers)
• Unique personal identifiers (cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; employee number, unique pseudonym, or user alias; telephone numbers or other forms of persistent or probabilistic identifiers that can be used to identify a particular employee or device)
• Signature
• Telephone numbers
• Medical/health information
• Insurance policy number
• Any information in an individual’s application and claims history, including appeals records, if information is linked or reasonably linkable to an individual or household, including via device, by business or service provider
• Education information
• Professional or employment-related information (including employment history)
• Biometric information (imagery of face;)
• Characteristics of protected classifications under California or federal law (race;; sex/gender (including pregnancy, childbirth, breastfeeding and/or related medical conditions);; age (40 and older);; national or ethnic origin;; union membership; disability (mental and physical, including HIV/AIDS, cancer, and genetic characteristics); citizenship or immigration status;; marital status; medical condition (genetic characteristics, cancer or a record or history of cancer); military or veteran status;; status as a victim of domestic violence, assault, or stalking; and requests for family care leave, for leave for an employee’s own serious health condition, or for pregnancy disability leave)
• Video information (CCTV video footage)
• Sensitive Personal Information. Personal information that reveals an individual’s Social Security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number [for corporate account] in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; genetic data; or the contents of an employee’s mail, email, and text messages unless the business is the intended recipient of the communication. The processing of biometric information for the purpose of uniquely identifying an individual. Personal information collected and analyzed concerning an individual’s health. Personal information collected and analyzed concerning an individual’s sex life or sexual orientation.

Sources of Personal Information

We collect Personal Information directly from you (California residents) and from recruiters; staffing companies; references; former employers; educational institutions; online providers (such as through LinkedIn and similar providers); government entities; other employees; business partners; payroll providers; benefits providers; medical providers; background checks; company bankers; claims handlers; authentication and single sign-on providers; advertising networks; internet service providers; professional employer organizations; data analytics providers; operating systems, platforms, or software; social networks; and data brokers. We do not collect all categories of Personal Information from each source.

Purposes for Collection

We currently collect and have collected the above categories of Personal Information for all purposes of providing employment, including to:

• Process payroll;
• Enable recruiting services;
• Request you complete applications and forms associated with your employment or prospective employment;
• Consider you for potential employment;
• Perform background checks and drug testing;
• Verify your ability to work in this country;
• Identify you as a veteran;
• Administer and maintain corporate bank accounts;
• Manage corporate expenses;
• Process security clearances;
• Perform diversity and inclusion initiatives, including data analysis, development, and deployment;
• Perform company audits;
• Request you acknowledge your agreement to certain company policies;
• Administer our wellness program;
• Administer and maintain benefits, including group health insurance, retirement accounts, employee compensation, and employee leave;
• Contact individuals for emergency purposes;
• Track time and attendance at work;
• Manage workers’ compensation claims;
• Manage your job-related performance;
• Arrange business travel;
• Investigate and handle disciplinary actions or termination;
• Establish training and/or development requirements;
• Detect lost/stolen equipment, fraud, or other types of wrongdoing;
• Grant and monitor your access to secure company facilities and files;
• Engage in corporate transactions requiring review of employee records and information, such as for evaluating potential mergers and acquisitions;
• Review web traffic and events, monitor for virus attacks and web content, and determine bandwidth consumption;
• Maintain commercial insurance policies and coverages, including for workers’ compensation and other liability insurance;
• Maintain commercial licenses for enterprise applications and platforms;
• Prevent the spread of illness and administer programs during a pandemic (e.g., COVID-19);
• Perform call monitoring and surveillance (e.g., CCTV);
• Comply with federal and state law;
• Enforce our legal rights; and
• Engage in other legitimate business purposes reasonably required for our day-to-day operations such as accounting, financial reporting, and business planning.

We also use your Personal Information for the purposes described in our IT Policy.

The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Effective Date of this Privacy Policy and, for each category, categories of recipients to whom we disclosed Personal Information.

We disclosed Personal Information to the above categories of recipients for all of the business or commercial purposes identified in the above “Purposes for Collection” section.

We have not sold or shared Personal Information in the twelve (12) months preceding the Effective Date of this Privacy Policy. We do not knowingly collect, sell, or share the Personal Information of individuals under 16 years of age.

We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with services you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us. Please contact us as described in the “How to Contact Us” section below for more information on our employee data retention schedule.

If you are a California employee, you have the following rights with respect to your Personal Information:

• The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling, or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
• The right to delete Personal Information that we collected from you, subject to certain exceptions;
• The right to correct inaccurate Personal Information that we maintain about you;
• If we sell or share Personal Information, the right to opt-out of the sale or sharing;
• If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
• The right not to receive discriminatory treatment by us for the exercise of privacy rights conferred by the CCPA.

You may submit a request to know, delete, and/or correct through our interactive webform available here, or by calling us at 877 856 1464.

If you submit a request to delete online, we may ask you to confirm separately that you want your Personal Information deleted.

If you are submitting a request on behalf of a California employee, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California employee.

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 contact legal@ennismore.com.

If you would like to update your personal information, such as to notify us of a change of name or address, or if you have questions about your employment, please contact your local People Team.

We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California employee on whose behalf you are making such request. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable. To do so, we will ask you to verify data points based on information we have in our records concerning you.

When we hire you, we provide you with other policies and procedures that govern your use of our offices, networks, computers, and other devices. We have the right to monitor your use of our offices and electronic resources in accordance with those policies and procedures.

For more information, please read our IT Policy You can find a copy of this Policy on Workplace  or by contacting the IT Team.

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below. Please also see our Accessibility Statement available here.

To contact us for questions or concerns about our privacy policies or practices please reach out to the Legal Team.