Notice At Collection - Western Growers Association Western Growers Association

Western Growers Family of Companies

Notice at Collection

for California Applicants, Candidates, and Employees

For the purposes of this Notice, the words “our,” “us,” “we,” and “Western Growers,” refer to Western Growers Association, its affiliated companies, and subsidiaries, including Western Growers Assurance Trust, Western Growers Insurance Services, Western Growers Financial Services, Western Growers Service Corporation, and Pinnacle Claims Management, Inc.

Western Growers collects and uses your personal information, including sensitive personal information, for human resources, employment, benefits administration, health and safety, legal compliance and for the business purposes listed under the headings below. We are committed to properly handling the personal information collected or processed in connection with your employment relationship with us.

If you are looking for our full privacy policy or information about how we collect personal information from visitors to our website (including applicants/candidates/employees) or users of our products and services, please review our Western Growers Privacy Policy.

We may collect the personal information and sensitive personal information categories listed below. Included, for each category, are the types of personal information collected, our stated business use purposes and whether the information is shared. We will not sell the personal information, including any sensitive personal information, we collect about applicants and candidates for employment or our employees.

For information on the retention period(s) for any personal information or sensitive personal information category listed below, please review the Western Growers’ Document Retention Policy (see the Employment, Employee, and Payroll Records section)

Personal Information

Identification data such as:

Your Full Name
Contact Information
Gender
Date of Birth
Signature
Social Security Number
Driver’s license or state identification numbers; and
Similar information for your dependents and beneficiaries

This information may be shared with various service providers. See Table A for additional information. Other than the service providers listed in Table A, this information is not shared with outside third parties except as required by law. We collect this information for the following business purposes:

Recruit and process employment applications, including verifying eligibility for employment and conducting background and related checks.
Conduct employee onboarding.
Maintain and administer payroll and employee benefit plans, including enrollment and claims handling.
Maintain personnel records and comply with record retention requirements.
Provide employees with human resources management services and employee data maintenance and support services.
Communicate with employees and their emergency contacts and plan beneficiaries.
Comply with applicable state and federal labor, employment, tax benefits, workers’ compensation, disability, equal employment opportunity, workplace safety, and related laws.
Prevent unauthorized access to or use of the Company property, including information systems, electronic devices, networks, and data.
Ensure employee productivity and adherence to Company policies.
Conduct internal audits and investigate complaints, grievances, and suspected violations of Company policy.
Respond to law enforcement requests and as required by applicable law or court order.
Exercise or defend the legal rights of the Company and its employees, and affiliates.

Employment and personal information such as:

Your name
Signature
Social Security number
Physical characteristics or description
Photograph
Address
Telephone number
Passport number
Driver’s license or state identification card number
Insurance policy number
Education
Current employment
Employment history
Membership in professional organizations
Licenses and certifications
Bank account number; or
Any other financial, medical or health insurance information.

Recruit and process employment applications, including verifying eligibility for employment and conducting background and related checks.
Conduct employee onboarding.
Maintain and administer payroll and employee benefit plans, including enrollment and claims handling.
Maintain personnel records and comply with record retention requirements.
Provide employees with human resources management services and employee data maintenance and support services.
Communicate with employees and their emergency contacts and plan beneficiaries.
Comply with applicable state and federal labor, employment, tax benefits, workers’ compensation, disability, equal employment opportunity, workplace safety, and related laws.
Prevent unauthorized access to or use of the Company property, including information systems, electronic devices, networks, and data.
Ensure employee productivity and adherence to Company policies.
Conduct internal audits and investigate complaints, grievances, and suspected violations of Company policy.
Respond to law enforcement requests and as required by applicable law or court order.
Exercise or defend the legal rights of the Company and its employees, and affiliates.

Protected classification characteristics under California or federal law such as:

Age (40 years or older)
Race
Color
Ancestry
National origin
Citizenship
Religion or creed
Marital status
Medical condition
Physical or mental disability
Sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions)
Sexual orientation
Reproductive health decision making
Military and veteran status; or
Genetic information (including familial genetic information)

Comply with applicable state and federal labor, employment, tax benefits, workers’ compensation, disability, equal employment opportunity, workplace safety, and related laws.
Maintain and administer payroll and employee benefits, including enrollment and claims handling.
Design, implement, and promote the Company’s diversity and inclusion programs.
Perform workforce analytics, data analytics, and benchmarking.
Conduct internal audits, grievances, and suspected violations of Company policy.
Exercise or defend the legal rights of the Company, its employees, and affiliates.

Commercial information, such as:

Transaction information
Purchase history
Financial details

Conduct employee onboarding.
Maintain and administer payroll and employee benefits, including enrollment and claims handling.
Prevent unauthorized access to or use of the Company property, including information systems, electronic devices, networks, and data.
Conduct internal audits and investigate complaints, grievances, and suspected violations of policy.
Respond to law enforcement requests and as required by applicable law or court order.
Exercise or defend the legal rights of the Company and its employees and affiliates.

Company internet or other similar network activity information, including:

All activity on the Company’s information systems (e.g., internet browsing history, search history, intranet activity, email communications, social media postings, stored documents and emails, usernames, and passwords).
All activity on communications systems (e.g., phone calls, call logs, voicemails, text messages, chat logs, app use, mobile browsing and search history, mobile email communications); and
Other information regarding an employee’s use of company-issued devices.
This information may be shared with various service providers. See Table A for additional information. Other than the service providers listed in Table A, this information is not shared with outside third parties except as required by law. We collect this information for the following business purposes:
Facilitate the efficient and secure use of Company information systems.
Ensure compliance with Company information systems policies and procedures.
Comply with applicable state and federal laws.
Prevent unauthorized access to, use, or disclosure or removal of the Company’s property, records, data, and information.
Enhance employee productivity.
Conduct internal audits and investigate complaints, grievances, and suspected violations of policy.
Exercise or defend the legal rights of the Company, its employees and affiliates.

Geolocation data, such as:

The time and physical location related to use of an internet website, application, or device; and
The time and physical location related to use of employee’s identification badge.
This information may be shared with various service providers. See Table A for additional information. Other than the service providers listed in Table A, this information is not shared with outside third parties except as required by law. We collect this information for the following business purposes:
Improve the safety of employees, customers, and the public regarding the use of the Company property and equipment.
Prevent unauthorized access, use, or loss of the Company property.
Ensure employee productivity and adherence to the Company’s policies.
Conduct internal audits and investigate complaints, grievances, and suspected violations of the Company’s policy.

Surveillance data such as:

Call monitoring (Call Center Personnel Only); and
Video surveillance (All WG office locations; reception, and public areas only).
This information may be shared with various service providers. See Table A for additional information. Other than the service providers listed in Table A, this information is not shared with outside third parties except as required by law. We collect this information for the following business purposes:
Prevent unauthorized access, use, or loss of the Company property.
Improve customer service.
Conduct internal audits and investigate complaints, grievances, and suspected violations of the Company’s policy.
Exercise or defend the legal rights of the Company, its employees, and affiliates.

Professional or employment-related information, such as:

Employment application information (e.g., work history, academic and professional qualifications, educational records, references, interview notes, background check, drug testing results, work authorization).
Performance and disciplinary records.
Salary, bonus, commission, and other similar compensation data.
Benefit plan enrollment, participation, and claims information.
Leave of absence information, including religious, military, and family obligations, health data concerning employee and their family members.
This information may be shared with various service providers. See Table A for additional information. Other than the service providers listed in Table A, this information is not shared with outside third parties except as required by law. We collect this information for the following business purposes.
Recruit and process employment applications, including verifying eligibility for employment, background checks, and onboarding.
Design and administer employee benefit plans and programs, including for leaves of absence.
Maintain personnel records and comply with record retention requirements.
Communicate with employees and their emergency contacts and plan beneficiaries.
Comply with applicable state and federal labor, employment, tax, benefits, workers’ compensation, disability, equal employment opportunity, workplace safety, and related laws.
Prevent unauthorized access to or use of the Company’s property, including its information systems, electronic devices, network, and data.
Ensure employee productivity and adherence to the Company policies.
Conduct internal audits and investigate complaints, grievances, and suspected violations of the Company policy.
Evaluate and provide useful feedback about job performance, facilitate better working relationships, and for employee professional development.
Exercise or defend the legal rights of the Company, its employees, and affiliates.

Non-public education information, such as:

Education records
Degrees and vocational certifications obtained
Report cards; and
Transcripts.

Evaluate an individual’s appropriateness for hire, promotion, or transfer to a new position at the Company.

Evaluate and provide useful feedback about job performance, facilitate better working relationships, and for employee professional development.

Personal Information Inferences

Inferences drawn from other personal information to create a profile or summary, for example, an individual’s preferences, abilities, aptitudes, and characteristics.
This information is not shared except as required by law. We collect this information for the following business purposes.
Engage in human capital analytics, including to identify correlations about individuals and job success, analyze data to improve retention and productivity, and analyze employee preferences to inform human resources policies and procedures.
Comply with applicable state and federal laws.

Sensitive Personal Information

Sensitive personal information is a subtype of personal information consisting of specific information categories. We may collect or use information that falls within the sensitive personal information categories listed below.

Government identifiers, such as:

Social Security number
Driver’s license
State identification card
Passport and visa information; and
Immigration status and documentation.

This information may be shared with various service providers. See Table B for additional information. Other than the service providers listed in Table B, this information is not shared with outside third parties except as required by law. We collect this information for the following business purposes.

Recruit and process employment applications, including verifying eligibility for employment and conducting background and related checks.
Process and administer payroll and employee benefits, including enrollment and claims handling.
Maintain personnel records and comply with record retention requirements.
Provide employees with human resources management services and employee data maintenance and support services.
Communicate with employees and their emergency contacts and plan beneficiaries.
Comply with applicable state and federal labor, employment, tax benefits, workers’ compensation, disability, equal employment opportunity, workplace safety, and related laws.
Prevent unauthorized access to or use of the Company property, including information systems, electronic devices, network, and data.
Respond to law enforcement requests and as required by applicable law or court order.

Complete account access credentials, such as:

Usernames
Account numbers
Phone number (used for WG business only)
Password

Recruit and process employment applications, including verifying eligibility for employment and conducting background and related checks.
Provide employees with human resources management services and employee data maintenance and support services.
Prevent unauthorized access to or use of the Company information systems, electronic devices, network, and data.

Racial or Ethnic Origin

Comply with federal and state equal employment opportunity laws.
Comply with federal and state reporting requirements.
Design, implement, and promote the Company’s diversity and inclusion programs.
Perform workforce analytics, data analytics, and benchmarking.
Conduct internal audits and investigate complaints, grievances, and suspected violations of policy.

Religious or philosophical beliefs

(Only when provided in connection with a request for religious reasonable accommodations). This information is not shared except as required by law. We collect this information for the following business purposes:

Review and process religious reasonable accommodation requests

Exercise or defend the legal rights of the Company and its employees and affiliates.

Mail, email, or text messages contents not directed to the Company.

Conduct internal audits and investigate complaints, grievances, and suspected violations of policy
Exercise or defend the legal rights of the Company and its employees and affiliates.

Health Information

(Including job restrictions and workplace illness and injury information.) This information may be shared with various service providers. See Table B for additional information. Other than the service providers listed in Table B, this information is not shared with outside third parties except as required by law. We collect this information for the following business purposes:

Investigate and process workers’ compensation claims.
Process health insurance claims.
Ensure equal access to retirement programs and fertility planning by same-sex spouses.
Exercise or defend the legal rights of the Company and its employees and affiliates.

If you have any questions about this Notice or need to access this Notice in an alternative format due to having a disability, please contact [email protected], call us at 877-942-4529 or write us at: Western Growers, 6501 Irvine Center Dr. Suite 100, Irvine, CA 92618.

If you would like more information on your rights as a consumer, please view our Notice of Consumer Rights.

Effective Date: July 1, 2023.

Appendix

Service Provider Information

The following tables identify service providers as referenced above, including links to their privacy policies.

TABLE A: PERSONAL INFORMATION

Data Category	Service Providers
Identification data; Protected classification characteristics under California or federal law	Employ, Inc., (Jobvite) Paycom NWPS For certain employees: Navan, Inc.
California Customer Records	Employ, Inc., (Jobvite) Halogen (Saba TalentSpace; Cornerstone) Paycom NWPS For certain employees: Navan, Inc.
Commerical Information	NWPS For certain employees: Navan, Inc.
Company internet or other similar network activity information	Microsoft Sonitrol Genesys
Geolocation Data	Sonitrol Employ, Inc., (Jobvite) Halogen (Saba TalentSpace; Cornerstone) Paycom NWPS For certain employees: Navan, Inc.
Surveillance Data	Sonitrol Genesys
Professional or employment related information	Employ, Inc., (Jobvite) Halogen (Saba TalentSpace; Cornerstone) Paycom NWPS
Non-public education information	Employ, Inc., (Jobvite) Halogen (Saba TalentSpace; Cornerstone)

TABLE B: SENSITIVE PERSONAL INFORMATION

Data Category	Service Providers
Government Identifiers	Employ, Inc., (Jobvite) Paycom NWPS E-Verify For certain employees: Navan, Inc.
Complete Account Access Credentials	Microsoft Employ, Inc., (Jobvite) Halogen (Saba TalentSpace; Cornerstone) NWPS Okta For certain employees: Navan, Inc.
Racial or ethnic origin	Employ, Inc., (Jobvite)
Mail, email, or text messages contents not directed to the Company	Microsoft
Health Information	CopperPoint Triage Now