Employee and Applicant Privacy Policy

Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household. It does not include publicly available information or lawfully obtained, truthful information that is a matter of public concern. Personal Information does not include aggregated or deidentified information.

Some Personal Information is defined as Sensitive Personal Information under California law. The Company does not collect or process Sensitive Personal Information to infer characteristics about applicants or employees.

The Company collects the following categories of Personal Information about employees and job applicants and has done so within the 12 months since this Policy was last updated:

• Identifiers: such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers
• Personal information described in the California Customer Records statute: such as name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or other financial information, medical information, or health insurance information
• Characteristics of protected classifications under California or federal law: such as race, national origin, religion, sex, gender, sexual orientation, disability, and age
• Commercial information: such as records of personal property, products, or services purchased
• Internet or other electronic network activity information: such as browsing history and search history
• Geolocation data: such as location information automatically captured by IT security systems
• Audio and visual information: such as audio and video captured by our office security systems and recordings of events, conferences, and meetings, and with an applicant’s consent where applicable, recordings or AI-assisted transcripts of interviews conducted during the recruiting process
• Professional and employment-related information: such as past and current employment history, employee performance, interview notes, recruiter evaluations, AI-generated draft interview summaries that are reviewed by Company personnel, and other recruiting-related assessments
• Education information subject to the federal Family Educational Rights and Privacy Act: such as student transcripts
• Inferences: drawn from any of the categories of information listed above to create a profile reflecting preferences, characteristics, and work-related tendencies

The Company collects Personal Information about employees and job applicants from the following sources:

• The employee or applicant
• The employee or applicant (via the Company’s human resources service providers)
• The applicant’s references
• Prior employers
• The Company’s internet content filtering and identity protection service providers
• Security systems at the Company’s office locations
• Online behavioral self-assessment tools (based on employee self-assessments)
• The Company’s recruiting and AI-assisted interview service providers

Fehr & Peers collects Personal Information about employees and job applicants for the following reasons:

• To communicate with the employee or applicant
• To administer the recruiting and employment application processes, including scheduling interviews, documenting interviews, preparing recruiter notes, and creating AI-assisted interview transcripts and draft summaries that are reviewed by Company personnel
• To administer the employment relationship, including providing human resources services, employee training and evaluation, and employee benefits
• To verify work eligibility
• To administer payroll and reimbursements
• To report affirmative action data
• To support business development efforts, including presenting employee qualifications to clients
• To verify eligibility for clients’ small, minority, or other disadvantaged business enterprise classifications
• To administer information technology services, including IT security
• To maintain security at the Company’s office locations
• To comply with federal, state, or local laws
• To cooperate with law enforcement agencies concerning conduct or activity that the Company reasonably and in good faith believes may violate federal, state, or local law.

Fehr & Peers discloses Personal Information about employees and job applicants to the following categories of third parties:

• Service providers that provide the Company with recruiting, employment application, interview documentation, and AI-assisted transcription support services and administration
• Service providers that provide the Company with human resources support services and administration
• Service providers that provide the Company with employment benefits support services and administration
• Service providers that provide the Company with payroll support services and administration
• Service providers that provide the Company with accounting support services and administration
• Service providers that provide the Company with information technology support services and administration
• To connect employees with third-party vendors, such as Uber, that provide work-related benefits to employees.

If needed, Fehr & Peers may also disclose Personal Information about employees and job applicants to the following categories of third parties:

• The Company’s insurance companies to make insurance claims or perform investigations
• The Company’s legal counsel to exercise or defend actual or potential legal claims or perform investigations
• Federal, state, and/or local agencies to comply with applicable laws or to comply or cooperate with an investigation
• Other third parties to comply with a court order or subpoena or to exercise or defend actual or potential legal claims

The Company retains Personal Information about employees for as long as necessary to fulfill the purposes described in this policy, including for the duration of employment plus up to 4 years thereafter, unless a longer retention period is required by law. The Company retains most information about job applicants for 4 years from creation. The criteria the Company uses to determine retention periods includes the length of time the Company has an ongoing relationship with the applicant or employee, the Company’s obligations under applicable law, and the potential for claims, litigation, investigations, or other legal or regulatory issues. Employees may find the Company’s Records Retention and Destruction Policy on the Hub. Interview notes, interview transcripts, and recruiter-approved interview summaries are retained in accordance with the Company’s records retention practices applicable to recruiting records.

The Company does not sell Personal Information of job applicants or employees and has not done so in the preceding 12 months. The Company does not share Personal Information of job applicants or employees with advertisers and has not done so in the preceding 12 months.

All job applicants and employees have the following privacy rights:

• The Right to Know: Applicants and employees have the right to request information about the Personal Information that Fehr & Peers collects, including the categories of information collected, the sources of that information, the purposes for its use, and the categories of third parties to whom it is disclosed, as well as the specific pieces of Personal Information collected about them.
• The Right to Delete: Applicants and employees have the right to request that Fehr & Peers delete Personal Information about them, subject to certain legal expectations.
• The Right to Correct: Applicants and employees have the right to request correction of inaccurate Personal Information maintained by the Company.
• The Right to Non-Discrimination: Fehr & Peers will not discriminate against applicants or employees for exercising their Privacy rights.

To exercise these rights, please contact Corporate Human Resources, email privacy@fehrandpeers.com, or send a request by mail to:

Fehr & Peers
100 Pringle Avenue, Suite 600
Walnut Creek, CA 94596

The Company may take reasonable steps to verify your identity before responding to a request.