Updated December 9, 2022
Personal information means all information that relates to an identified individual or to an identifiable individual. For example, your name, address, email address, educational and employment background, resume, and job qualifications.
WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL INFORMATION
CATEGORIES OF PERSONAL INFORMATION WE PROCESS
We process personal information that you provide directly to us, such as when you register as an an employee in the Welcome Wagon processing system, submit a job application on our sites or in connection with a recruiting event, or when conducting a remote or in-person interview. We may also receive personal information about you from other sources, such as from references, in connection with background or employment checks, target companies where Welcome Wagon conducts due diligence related to a potential acquisition of your employer, and from third-party sources like professional headhunters or recruiting firms, data brokers or if allowed by applicable law other sources such as our sites. Sites include, without limitation, social sites where you have created a public page or profile or otherwise given permission so that recruiters can access your information on these sites. They also can include vendor sites where Welcome Wagon has invited you to participate in assessments, evaluations, or online interviews. Welcome Wagon may process the following categories of personal information for our recruitment and employment activities as further described herein: (i) name and contact details; (ii) educational background; (iii) employment background; (iv) job qualifications and work eligibility; (v) jobs in which you have expressed an interest or for which you would like to submit an application; (vi) resume or transcripts, and any supporting documentation attached to your resume such as copies of certificates and diplomas; (vii) employment references; (viii) compensation details, such as salary information; (ix) background check information, such as a verification of your educational and professional background, and other relevant information subject to Welcome Wagon policies and applicable laws; (x) information about your personality, competency, ability and suitability for a position; and (xi) certain types of sensitive personal information as described below.
WHERE WE SOURCE YOUR PERSONAL INFORMATION
We process personal information you provide directly to us in connection with the below purposes, such as when you submit a job application or interview with us, or during the onboarding process. We also receive personal information from other sources, such as during reference, background, or employment checks, and from third party recruitment sources and assessment sites.
We reserve the right to monitor employees’ use of our equipment, devices, computers, network, applications, software, and similar assets and resources for the safety and protection of employees and intellectual property. In the event such monitoring occurs, it may result in the collection of personal data about you. If required by applicable law, we will notify you of such monitoring and obtain your consent.
WHY AND HOW WE USE YOUR PERSONAL INFORMATION
We process information about you to connect the right candidate with the right job at Welcome Wagon and evaluate whether you are the right applicant for a position. In turn, we may include information about you in our recruitment databases to manage Welcome Wagon’s candidate selection and recruiting processes. If you are selected for a position at Welcome Wagon, information about you will also be used to facilitate the hiring process. Please be aware that, prior to hiring you and for Welcome Wagon to be able to extend an offer to you, you may be requested to complete a background check in accordance with Welcome Wagon policies and local law.
We use personal information for the following purposes: to communicate with you and respond to your requests or application; for recruitment, evaluation, background screening and hiring purposes; to analyze, develop and improve our processing system, our recruiting activities and Welcome Wagon products and services; to provide and administer remuneration, salary, benefits, and incentive schemes and providing relevant information to payroll and to enable your use of the Welcome Wagon processing
system; to conduct surveys for benchmarking and identifying improved ways of working employee relations and engagement at work (these will often be anonymous but may include profiling data such as age to support analysis of results); to manage conduct, performance, capability, absence, and grievance related reviews, allegations, complaints, investigations, and processes and other informal and formal HR processes and make related management decisions; to process information about absence or
medical information regarding physical or mental health or condition in order to assess eligibility for incapacity or permanent disability related remuneration or benefits, determine fitness for work, facilitate a return to work, make adjustments or reasonable accommodations to duties or the workplace and make management decisions regarding employment or engagement or continued employment or engagement or redeployment and conduct related management processes; to monitor programs to
ensure equality of opportunity and diversity with regard to personal characteristics protected under local anti-discrimination laws; to maintain the security of our processing system and our sites, systems and networks; to comply with applicable laws and regulations and to operate our business; to make internal human resource decisions; to evaluate internal candidates for positional hires; and other purposes permitted by applicable privacy and data protection legislation including where applicable, our legitimate interests where this is not overridden by the interests or fundamental rights and freedoms of employees.
HOW WE MAY SHARE YOUR PERSONAL INFORMATION
Welcome Wagon employees are authorized to access personal information only to the extent necessary to serve the applicable purpose(s) and to perform their jobs and are bound by appropriate confidentiality agreements.
Where necessary, we share personal information with third parties as described below:
Depending on your state of residence, you may have certain choices and rights in relation to our use of information about you, such as the right to access, correct and update, erase, or delete, and obtain a copy of your personal information. Candidates and employees may exercise these choices in accordance with applicable laws by contacting Human Resources. We reserve the right not to grant access to personal data that we hold about you if access is not required by applicable law. There are also
instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all the personal data that we hold about you. In addition, personal data may have been destroyed, erased, or made anonymous. If we cannot provide you with access to your personal data, we will inform you of the reasons why subject to any legal or regulatory restrictions.
HOW LONG DO WE RETAIN PERSONAL INFORMATION
Welcome Wagon maintains your personal information as long as required by applicable law. You may request that we delete the personal data about you that we hold, provided that we reserve the right not to grant such request if we are not required to delete personal data under applicable law. There are instances where applicable law or regulatory requirements allow or require us to refuse to delete this personal data. In the event that we cannot delete your personal data, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
To the extent permitted or required by law, or as requested by you, Welcome Wagon may delete your personal information at any time. As a result, you should retain your own copy of any information you submit to us. In some cases, in order to comply with applicable law or a legal obligation, Welcome Wagon may deny your request to delete personal information and may retain your personal information for longer than five (5) years.
HOW YOUR PERSONAL INFORMATION IS SECURED
Welcome Wagon has implemented appropriate technical, physical, and organizational measures designed to protect your personal information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access as well as all other forms of unlawful processing (including, but not limited to, unnecessary collection) or further processing.
SENSITIVE PERSONAL INFORMATION
According to California law, “sensitive personal information” is personal information that reveals (a) your Social Security or other state identification number; (b) your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) your geolocation; (d) your racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of your mail, email, or text messages, unless we are the intended recipient of the communication; and (f) your genetic data. In addition, “sensitive personal information” includes processing of biometric information for purposes of identifying you; personal information collected and analyzed concerning your health, and personal information collected and analyzed concerning your sex life or sexual orientation. Welcome Wagon not only respects but celebrates diversity and inclusion in its workforce. As part of Welcome Wagon’s efforts to create and foster a diverse and inclusive workforce and/or to monitor equal opportunity, Welcome Wagon may request and process sensitive personal information related to age. You may also voluntarily disclose sensitive personal information including gender identity, preferred pronouns, sexual orientation, language, abilities/disabilities, veteran status, race, ethnicity, or other defining characteristics with Welcome Wagon during the recruiting process for the purposes set out in WHY AND HOW DO WE USE YOUR PERSONAL INFORMATION above. If not expressly required by the job listing, Welcome Wagon does not otherwise require applicants or candidates to disclose this information in connection with a job application or as part of our recruiting efforts. However, if you
elect to share such information with Welcome Wagon, it will not be used in the hiring or selection process or to determine eligibility for any role.
Written inquiries may be addressed to:
5830 Coral Ridge Drive, Ste 240
Coral Springs, FL 33076