Workforce Privacy Notice

Last modified December 2022

 Scope: Perfect Snacks LLC Workforce in California, U.S.A.

We recognize the value of your Personal Information.   We adhere to and respect the privacy rights of our workforce.  We have created this Workforce Privacy Notice to provide transparency about how we collect, use, and process your Personal Information in the employment context, and how you can contact us if you have additional questions about how We protect the Personal Information entrusted to us. 

Please read this Notice carefully to understand our policies and practices regarding your Personal Information. This Notice may change from time to time. We will inform you about material changes by posting a notice on our Corporate Policy Center and on top of this Notice for a reasonable period of time and changing the “Last modified” date.

 

Click here to see the full notice

  • To whom does this Privacy Notice apply?
  • What Categories of Personal Information do We collect and process?
  • What are the sources of the Personal Information We collect?
  • Why do We collect and how do We use your Personal Information?
  • How do we share and disclose your Personal Information?
  • Security
  • California Rights
  • Retention Periods
  • Contact Us

 

  1. To whom does this Privacy Notice apply?

 

Perfect Snacks LLC (“Company” “we”, “us”, “our”), provides this Workforce Privacy Notice (“Notice”) to explain our practices regarding the collection, use, and other processing activities of certain individually identifiable information about members of the Company workforce in California (“Personal Information”).  Effective January 1, 2023, the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”) (collectively, “California Privacy Law”) gives certain rights to California residents, including employees. This Notice explains how We use Personal Information about you in an employment context and summarizes the rights you have as a California resident, including the right to receive a portable copy of your data and to not be discriminated against for choosing to exercise your rights.

 

To the extent you work on our premises, use any computer systems We own, or connect to any networks we operate, your actions and communications may be observed, monitored, recorded, tracked, filtered, deleted, and otherwise processed for our business and compliance purposes.  All telephone conversations or transmissions, electronic mail or transmissions, or Internet access or usage by an authorized Company user of an electronic device or system, including the use of a computer, telephone, wire, radio or electromagnetic, photo-electronic or photo-optical systems, may be subject to monitoring at any time and by any lawful means.  We do not sell your Personal Information or share it for cross‐context behavioral advertising.  We do not engage in providing financial incentives for the disclosure of California Personal Information. We do not engage in any use or disclosure of sensitive Personal Information (“Sensitive Personal Information”) except as necessary to provide benefit services or as otherwise permitted by California Privacy Law to comply with federal, state, or local laws.

 

  1. What Categories of Personal Information do We collect and process?

 

We collect various types of Personal Information about you in connection with your work at the Company when it is needed to fulfill specific business and legal/compliance requirements including but not limited to the categories of Personal Information listed below.  Some of the following categories of Personal Information may be supplied by you voluntarily under your sole discretion (for example, certain characteristics of protected classifications).

 

  • Identifiers: including name and home contact information (e.g. postal or residential address, personal email address, telephone number, emergency contact), date of birth, social security number, driver’s license, passport or other similar identifiers.

 

  • Payroll and benefits information, including financial information, such as salary, bank account details, corporate payment card usage, employment benefits, information about your dependents, or other similar identifiers.

 

  • Characteristics of protected classes, including racial or ethnic origin, gender, citizenship, disability information (if provided voluntarily), maternity leave information, veteran or military status (if provided voluntarily), religious or philosophical beliefs (if provided voluntarily), and sexual orientation (if provided voluntarily).

 

  • Internet and other electronic network activity information, including communication information and computer usage information related to your use of Company equipment, systems, and other resources [including the contents of mail, email and text messages.

 

  • Geolocation data, including precise location.

 

  • Audio, electronic, visual or similar information, including in connection with use of Company systems, such as voicemail, as well as CCTV and security monitoring systems.

 

  • Recruitment information, including CVs, resumes, application forms;

 

  • Education information, including, in addition to identifiers and other data mentioned, education, training, degrees, and professional certifications;

 

  • Professional or employment-related information, including employee status, organization information, performance and talent information, employment background, functional experience, leadership experience, honors or awards, background information commonly used for security screenings, qualifications, evaluations, developmental planning, career interest and development information, and other talent management and team based assessments;

 

  • Inferences drawn from the information collected, including those related to abilities and performance; and

 

  • Other information, including sick day information, work-related accidents information, trade union membership, and any other information reasonably necessary for us to carry out our legal or regulatory obligations.

 

Sensitive Personal Information.  Certain Personal Information that We collect about our employees may be considered sensitive personal information (“Sensitive Personal Information”) within the meaning of California Privacy Law: social security number (for pay-roll related and background check purposes); driver's license number and passport number (for travel-related purposes); bank account number or financial account number (for payroll-related purposes); precise geolocation (for security,  system monitoring, and, in the case of our fleet drivers, for efficient routing, tracking miles traveled, and calculating work time); racial or ethnic origin, religious or philosophical beliefs, union membership, and information about sexual orientation (for inclusion, diversity, and related purposes); the contents of mail, email and text messages unless the Company is the intended recipient (for security and system monitoring); and health/medical information (for benefits, sick leave, and related purposes).

 

  1. What are the sources of the Personal Information We collect?

 

We generally receive Personal Information directly from you or from third parties, such as third party service providers that assist with health and safety, travel and expense, and other employment-related purposes described below. 

 

We only use and disclose Sensitive Personal Information as necessary to provide benefit services or as otherwise permitted by California Privacy Law to comply with federal, state, or local laws.

 

California employees are responsible for providing accurate and complete Personal Information when this Personal Information is requested for legitimate business or legal/compliance purposes and for ensuring that the information remains current.

 

  1. Why do We collect and how do We use your Personal Information?

 

Generally, we use PI for employment-related business purposes, including:

 

  • Workforce Planning and Recruitment, including job advertising, interviewing, selecting, hiring new staff, verifying employment references, conducting background checks, and related assessments;

 

  • Management and Administration, including employee career development, compensation and benefits and performance management;

 

  • Performance of Our Business Operations, including carrying out our day to day business activities, including surveys (for example to improve our processes), to communicate with you and for collaboration among our workforce;

 

  • Training and coaching, including identifiers, contact information, video and audio information; age; education, title.

 

  • Legal and Regulatory Compliance, including compliance with health & safety requirements and other legal or fiscal obligations, monitoring diversity and inclusion programs, participating in due diligence activities for the sale or purchase of a business, or in connection with litigation or an internal investigation or audit;

 

  • Security Management, including activities related to ensuring the security of our premises, assets, information, and individuals.

 

  1. How do we share and disclose your Personal Information?

 

  1. Within the Company

 

We restrict access to employee Personal Information to people within the Company who have a “need to know” that information. As a global Company doing business across national borders, there are many situations where this “need to know” requires your Personal Information to be transferred to the Company in another country or it may be stored in systems based in another country, including countries that may not offer a level of protection equivalent to that of the country in which you reside.  

 

  1. Outside the Company

 

We collect employee Personal Information for the business purpose described in the “To whom does this Privacy Notice apply“ section above. We share and/or disclose your employee Personal Information as follows:

Business Purposes. We share employee Personal Information with authorized third party service providers, such as compensation and benefits providers that have a “need to know” that information to provide services for us.  Where it does so, we impose appropriate contractual obligations regarding employee Personal Information on third party service providers.

Beyond our third party service providers, generally, We will only disclose your employee Personal Information outside the Company and its third party service providers:

  • when required to do so by law;
  • in response to a legitimate request for assistance by the police or other law enforcement agency;
  • to seek legal advice from the Company’s external lawyers or in connection with litigation with a third party;
  • in connection with the sale, purchase or merger of a business;
  • to provide a third party (such as a potential supplier or customer) with a means of contacting you in the normal course of business, for example, by providing your contact details, such as your business phone number and email address; or to protect your vital interests or safety.

 

  1. Security

 

The security and confidentiality of your Personal Information matters to us.  That’s why we have technical, administrative, and physical controls in place to protect your Personal Information from unauthorized access, use, and disclosure.  Our outside service providers must also protect your Personal Information and use it only to meet our business needs.  We also take steps to protect our systems from unauthorized access.  And we comply with all laws that apply to us, including California laws. 

 

  1. California Rights

 

Subject to certain exceptions detailed in the California Privacy Law, as a California resident, you have the right to request: (i) deletion of your PI; (ii) correction of inaccurate PI; (iii) the right to know/ access the categories of PI that we collect about you, including the specific pieces of PI; and (iv) the right to know the categories of PI disclosed for a business purpose.

Submitting a Verifiable Request.  If you are a member of our workforce in California or are applying for a job with us as resident in California and wish to request the exercise of these rights as detailed above or have questions regarding the employee Personal Information collected or shared with third parties, please send an email to workforceprivacy@perfectsnacks.com with the subject line “California Privacy Rights Request” or contact us at (888) 564-4606 (toll-free). When submitting your request, please include the specific nature of your request, referring to the specific right you wish to exercise, as well as your first and last name, email address, and zip code or mailing address. The Company may apply any exceptions or other conditions available under law when responding to correction, deletion, or other requests. We will generally fulfil requests for access, correction, deletion and other rights under California Privacy Law within 45 days of receiving a valid request. We may extend the respond time by another 45 days by notifying the individual of the time extension.

 

Authorized Agents. To the extent that you elect to designate an authorized agent to make a request on your behalf, they must provide appropriate documentation including written signed permission from you, proof of your identity, and a valid certificate of registration as an Agent before the California Secretary of State; or a valid, designated Power of Attorney (POA) as defined under the California Probate Code. Agent requests must be submitted to workforceprivacy@perfectsnacks.com with the subject line “California Privacy Rights Request”. When submitting the request, please include the specific nature of the request,  referring to the specific right you wish to exercise, as well as your first and last name, email address, and zip code or mailing address.  

 

We will not retaliate against you based solely upon your request to exercise your rights under California Privacy Law.

 

  1. Retention Periods

 

We store your Personal Information strictly and to the extent necessary for the performance of our obligations, and for the time necessary to achieve the purposes for which the Personal Information was collected, in accordance with our record retention obligations, legal holds, or any applicable laws.  When we no longer need to use your Personal Information, we will remove it from our systems and records and/or take steps to properly render it unintelligible, unless a legal reason exists to retain it.

 

  1. Contact Us

 

If you have any questions about this Workforce Privacy Notice, contact us at DataProtectionOfficeNA@mdlz.com.  We will respond to you in writing within a reasonable time.