MacroSource, LLC Data Privacy Notice for Staff Members and Applicants
Effective: December 7, 2023
1. Introduction &nbsp; &nbsp; 1.1 MacroSource, LLC (the &ldquo;Company&rdquo;, &ldquo;we&rdquo;, &ldquo;our&rdquo; or &ldquo;us&rdquo;) offers this Data Privacy Notice to describe how we handle personal information that we hold about our staff, their dependents, and job applicants (collectively referred to as &ldquo;you&rdquo; or &ldquo;your&rdquo;). The term &ldquo;staff member&rdquo; includes employees as well as those who work on a non-permanent basis, including contingent workers, temporary and contract workers, independent contractors, consultants, professional advisors, secondees, and interns. &nbsp; &nbsp; 1.2 This Notice describes the personal information that we collect and process about you, the purposes of the processing, and the rights that you have in connection with it.&nbsp; &nbsp; &nbsp; 1.3 If you are a California resident, please refer to the section 6, &ldquo;Your California Privacy Rights&rdquo; below for additional information regarding our collection, use, and disclosure of your personal information.&nbsp; &nbsp; &nbsp; 1.4 If you are in any doubt regarding the applicable standards, or have any comments or questions about this Notice, please contact us at the contact details in section 8, &ldquo;Contact details&rdquo; below.
2. Types of personal information we collect&nbsp; &nbsp; &nbsp; 2.1 In the course of your employment with the Company, or in the course of process of assessing potential employment, we process personal information about you, your dependents, beneficiaries, and other individuals. &nbsp;We collect such information from you, your references, other staff members, service providers, benefit providers and social media. &nbsp; &nbsp; 2.2 The types of personal information we process include, but are not limited to:&nbsp; &nbsp; &nbsp; &nbsp; &nbsp; (a) Identifiers &ndash; such as your name, date of birth, social security number, staff member ID, home and business address, telephone/email addresses, emergency contact details, passport number/national ID number; &nbsp; &nbsp; &nbsp; &nbsp; (b) Financial, medical, or health insurance information &ndash; such as banking details, tax information, equity grants, withholdings, salary, benefits, and expenses;&nbsp; &nbsp; &nbsp; &nbsp; &nbsp; (c) Demographics, such as gender, marital status, military service, ethnic background and disability status; &nbsp; &nbsp; &nbsp; &nbsp; (d) Work eligibility information, such as immigration and visa status; &nbsp; &nbsp; &nbsp; &nbsp; (e) Internet or other electronic network activity information associated with Company IT systems, networks, and resources &ndash; such as IP addresses, log files, electronic communications and files, network connections, and login credentials; &nbsp; &nbsp; &nbsp; &nbsp; &nbsp; (f) Geolocation data;&nbsp; &nbsp; &nbsp; &nbsp; &nbsp; (g) Video recordings in certain work areas and photographs for identification purposes; &nbsp; &nbsp; &nbsp; &nbsp; (h) Recordings of communications for quality control and training purposes; &nbsp; &nbsp; &nbsp; &nbsp; (i) Professional or employment-related information &ndash; such as job title/position, office location, employment contract, dates of service, positions held, performance and disciplinary records, grievance procedures, travel and expenses, work location preferences, investigations, complaints, sickness/holiday records, academic/professional qualifications, CV/r&eacute;sum&eacute;, criminal records data (for vetting purposes, where permissible and in accordance with applicable law), reference information, and information relating to background checks;&nbsp; &nbsp; &nbsp; &nbsp; &nbsp; (j) Education information, such as degrees or certifications held, trainings and development programs attended, and assessments; &nbsp; &nbsp; &nbsp; &nbsp; (k) Sensitive personal information, such as government identification numbers, login credentials, personal communications content when you use our information assets, biometrics, and health information. as described above and defined under applicable law; and&nbsp; &nbsp; &nbsp; &nbsp; &nbsp; (l) Inferences drawn from the above.&nbsp; We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to: &nbsp; &nbsp; &bull; Maintain business records for analysis and/or audit purposes;&nbsp; &nbsp; &nbsp; &bull; Comply with record retention requirements under the law or other relevant legal or regulatory requirements or internal document retention policy;&nbsp; &nbsp; &nbsp; &bull; Defend or bring any existing or potential legal claims; and&nbsp; &nbsp; &nbsp; &bull; Deal with any complaints regarding the services.&nbsp;
3. Information we disclose&nbsp; &nbsp; &nbsp; 3.1 We may disclose certain categories of your personal information for our business purposes in the following circumstances:&nbsp; &nbsp; &nbsp; &nbsp; &nbsp; (a) Service providers: We engage service providers that perform services to help us administer HR and staff member compensation and benefits, facilitate our recruiting efforts, assist us with facilitating our employment relationship with you, and operate our business, including compliance related activities. Unless otherwise specified, these companies will only use your personal information in the ways described in this Policy. &nbsp; &nbsp; &nbsp; &nbsp; (b) Benefit providers: &nbsp;We arrange for you to receive certain benefits from third parties and we share information with those parties to facilitate the provision of those services.&nbsp; &nbsp; &nbsp; &nbsp; &nbsp; (c) Consultants: &nbsp;We may provide personal information to consultants and advisors who help us operate and improve our business, including compliance related activities. &nbsp; &nbsp; &nbsp; &nbsp; &nbsp; (d) Marubeni group companies: The Company has affiliates around the world. We may disclose your personal information to Marubeni group companies for employment, recruiting, security, and internal reporting purposes. Unless otherwise specified, Marubeni group companies will only use your information in the ways described in this Policy. &nbsp; &nbsp; &nbsp; &nbsp; (e) To comply with law or cooperate with reasonable requests: We may disclose your personal information to law enforcement agencies, courts, other government authorities or other third parties where we believe necessary to comply with a legal or regulatory obligation. We may disclose personal information as we deem reasonably necessary to support lawful investigations or otherwise to protect our rights or the rights of you or any other party. &nbsp; &nbsp; &nbsp; &nbsp; &nbsp; (f) In the context of a transaction: We may disclose your personal information to potential transaction partners, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell or transfer all or a portion of our assets or business. &nbsp; &nbsp; 3.2 We disclose the following categories of your personal information to these parties for our business purposes: &nbsp; &nbsp; &nbsp; &nbsp; &nbsp; (a) Identifiers; &nbsp; &nbsp; &nbsp; &nbsp; (b) Demographics; &nbsp; &nbsp; &nbsp; &nbsp; (c) Financial, medical, or health insurance information;&nbsp; &nbsp; &nbsp; &nbsp; &nbsp; (d) Work eligibility information; &nbsp; &nbsp; &nbsp; &nbsp; (e) Geolocation data; &nbsp; &nbsp; &nbsp; &nbsp; (f) Internet or other electronic network activity information; &nbsp; &nbsp; &nbsp; &nbsp; (g) Pictures, audio, and video; &nbsp; &nbsp; &nbsp; &nbsp; (h) Professional or employment-related information;&nbsp; &nbsp; &nbsp; &nbsp; &nbsp; (i) Education information; and &nbsp; &nbsp; &nbsp; &nbsp; (j) Sensitive personal information.
4. Anti-Corruption Hotline &nbsp; &nbsp; 4.1 MacroSource, LLC has established a compliance hotline called EthicsPoint. EthicsPoint is operated by NAVEX Global, Inc. on behalf of Marubeni group, including MacroSource. &nbsp; &nbsp; 4.2 The Ethics Hotline and Website is a confidential, anonymous reporting system available to all employees that can be used to report any suspected breach of ethics or misconduct. To file a confidential, anonymous report with EthicsPoint, employees may either:&nbsp; &nbsp; &nbsp; &nbsp; &nbsp; &bull; Click on the &ldquo;Ethics Hotline&rdquo; icon on the intranet homepage; or&nbsp; &nbsp; &nbsp; &nbsp; &nbsp; &bull; Call the EthicsPoint Hotline at 1-833-609-1715 &nbsp; &nbsp; 4.3 EthicsPoint is a comprehensive and confidential reporting tool to assist MacroSource management and employees to work together to address fraud, abuse and other misconduct in the workplace, all while cultivating a positive work environment. &nbsp; &nbsp; 4.4 The operation of EthicsPoint may involve the processing of personal information about both MacroSource staff and third parties. Any personal information collected through EthicsPoint will be processed fairly and lawfully in accordance with applicable data protection laws for the sole purpose of identifying and investigating allegations of illegal activity and/or non-compliance with MacroSource policies.
5. Purposes for processing personal information Recruitment purposes &nbsp; &nbsp; 5.1 If you are applying for a role at the Company, then we collect and use this personal information primarily for recruitment purposes &ndash; in particular, to determine your qualifications for employment and to reach a hiring decision. This includes assessing your skills, qualifications and background for a particular role, verifying your information, carrying our reference checks or background checks and checking visa status and/or eligibility to work (where applicable) and to generally manage the hiring process and communicate with you about it. &nbsp; &nbsp; &nbsp; 5.2 If you are accepted for a role at the Company, the information collected during the recruitment process will form part of your ongoing staff member record.&nbsp; &nbsp; &nbsp; 5.3 If you are not successful, we may still keep your application to allow us to consider you for other suitable openings within the Company in the future. Employment or work related purposes &nbsp; &nbsp; 5.4 Once you become a staff member at the Company, we collect and use this personal information for the purpose of managing our employment or working relationship with you &ndash; for example, your employment records and contract information (so we can manage our employment relationship with you), your bank account and salary details (so we can pay you), your disability status (for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws and for government reporting obligations), information about your physical or mental condition (to provide work-related accommodations, health and insurance benefits to you and your dependents, to manage absences from work, or to manage pay and disability benefits), and details of your spouse and dependents (for emergency contact and benefits purposes). When you provide us with information about your spouse or dependents, it is your responsibility to inform them about the purposes for which the Company will process their information and bring this Notice to their attention.
We process rotational staff members' personal information through a global human resources system (&ldquo;HR System&rdquo;), which is a tool that helps us to administer HR and staff member compensation and benefits at an international level and which allows staff members to manage their own personal information in some cases. [The Company also uses an service provider to manage employee performance and appraisals and various systems to administer HR and staff member compensation and benefits.]
We use workforce analytics for succession planning, workforce management, data security. &nbsp;For instance, we use workforce analytics to assist in planning succession and to ensure business continuity, to design employee retention programs and diversity initiatives, to offer training opportunities and to identify patterns in the use of technology systems to information entrusted to us as well as to protect our associates and property. &nbsp;
Facilitating communication with you, ensuring business continuity, property management (e.g. laptops and mobile phones), providing references, protecting the health and safety of associates and others, safeguarding IT infrastructure, office equipment and other property, facilitating communication with you, your nominated contacts in an emergency. &nbsp;
We collect information about the use of Company information assets and resources, including internet access, electronic communications, and application usage. &nbsp;We collect this information to assess compliance with applicable laws and policies, to protect Company resources against unauthorized access, and to prevent crime and fraud. &nbsp;
The Company global directory&nbsp; &nbsp; &nbsp; 5.5 We maintain a global directory of staff members which contains your professional contact details (such as your name, location, job title and contact details). This information will be available to everyone in MacroSource to facilitate global cooperation, communication, and teamwork. Staff members can upload their photo as an icon on their emails and/or Beehive. Where staff members do this, their photo will also be processed by MacroSource. Other business purposes &nbsp; &nbsp; 5.6 We may also collect and use personal information when it is necessary for other business purposes, such as to help us conduct our business more effectively and efficiently &ndash; for example, for general HR resourcing on a global level, accounting purposes, or financial planning. We may also process your personal information to investigate violations of law or breaches of our own internal policies.&nbsp; &nbsp; &nbsp; 5.7 We collect and use personal information to provide information technology and information processing support, IT applications and systems maintenance, data storage, and IT facilities (including cloud-based solutions) in support of the Company&rsquo;s activities relating to its business including internal management and administration. Compliance-related purposes &nbsp; &nbsp; 5.8 We also may use your personal information where we consider it necessary for complying with laws and regulations or as reasonably necessary to exercise or defend the legal rights of MacroSource, including collecting and disclosing staff member personal information as required by law (e.g., for tax, health and safety, anti-discrimination laws), pursuant to court orders or other legal process, or subject to requests from government authorities or other parties.&nbsp; MacroSource Compliance Hotline &nbsp; &nbsp; 5.9 We may also use your personal information as required to operate the EthicsPoint, including to enable MacroSource, the Company and/or any relevant entities/individuals to process, analyze, recognize, resolve and/or otherwise address any issues or circumstances in which the Company and/or any of its staff have actually or allegedly been involved in any acts relating to bribery, money laundering, illegal accounting treatment, violation of securities laws such as insider trading, and other actual or potential criminal or unethical activity.
6. Your California Privacy Rights
This section provides California residents with additional information regarding our collection, use, and disclosure of their personal information.&nbsp;
We do not &ldquo;sell&rdquo; [or &ldquo;share&rdquo;] your personal information as those terms are defined under California law.&nbsp;
We do not use or disclose your sensitive personal information for purposes other than those described under California law.&nbsp;
You may have rights in relation to your personal information under California law, as described below. In the event you would like to exercise one of your rights or if you are an authorized agent submitting a request on behalf of a California consumer, please contact us at MacroSourceHR@macrosource.com or 912-436-3380. We will ask you to provide name and contact information. &nbsp;Please note that we may require additional information from you in order to honor your request, and we may decline your request as permitted under applicable law.&nbsp;
&nbsp; &nbsp; &bull; Right to know: Users exercising this right may request information about the personal information that we collect, use, disclose, share and sell;&nbsp; &nbsp; &nbsp; &bull; Right to deletion: Users exercising this right can ask us to delete their personal information we have collected;&nbsp; &nbsp; &nbsp; &bull; Right to correct: Users exercising this right can ask us to correct inaccurate personal information that we maintain about them; and &nbsp; &nbsp; &bull; Right to be free from discrimination: Employees may freely exercise these rights without fear of retaliation.&nbsp;
7. Updates to this Notice &nbsp; &nbsp; 7.1 This Notice may be updated periodically to reflect any necessary changes in our privacy practices. In such cases, please reference the MacroSource Company Policy SharePoint site. We encourage you to check back at the Company SharePoint site periodically in order to be aware of the most recent version of this Notice and the most current Company Privacy Policy.
8. Contact details &nbsp; &nbsp; 8.1 Please address any questions or requests relating to this Notice to privacy@macrosource.com or alternatively, you can raise any concerns with your HR department.&nbsp;