Data Privacy Notice for E.U. Employees and Contractors
This Notice describes Footprint LLC practices with respect to the collection, use, storage, and disclosure (“processing”) of Personal Information of employees and contractors covered by the European Union’s General Data Protection Regulation. This Notice applies to Footprint LLC, with global headquarters at 250 E Germann Rd, Gilbert, AZ 85297, as well as to its affiliated legal entities and branches (collectively “Footprint”, “us” or “our”) solely with respect to employees or contractors of Footprint’s operations in the European Union. All such persons (referred to below as “you” or “your”) should carefully read the provisions of this Privacy Notice.
“Personal Information,” as used in this Notice, means any information that can be used to identify you, whether directly or indirectly, including by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.
You can contact Footprint’s Chief Marketing Officer with any questions about this notice, our data collection practices, or your rights. You can reach the Chief Marketing Officer, Susan Koehler at: 250 E Germann Rd, Gilbert, AZ 85297, or by +1 (480) 550-9401, or by: firstname.lastname@example.org (the “Contact Persons”).
This general notice may be supplemented by additional notices at the point of any data collection. We may modify the manner in which we collect and process personal data from time to time and will advise you of any such changes. If you have specific questions about any of the data processing activities described in this or any other notice, please contact the Contact Persons.
The Information We Process About You
We process the information we collect from you directly or indirectly, either during our communications with you, when you apply for work (either as an employee or a contractor, when you sign up for benefits, or when you make use of Footprint equipment and systems, facilities, programs, resources, and services provided by third-party vendors utilized by Footprint. Any such third-party vendors will collect and process your personal data in a manner consistent with this Notice and in accordance with applicable law. This includes information about your employment history (including your history with Footprint), your job performance, compensation and benefits, and your dependents and emergency contacts.
In some cases, certain information will be required in order for Footprint or third-party vendors used by Footprint to determine your eligibility for work, compensation, promotion, benefits, or to otherwise provide you with the services you are requesting. We will mark that information as “Required” or “Mandatory.” Failure to provide required or mandatory information may result in your being denied work, promotion, benefits, or access to other services that Footprint, or third-party vendors used by Footprint, offers.
We use automated decision-making processes to process your data in certain contexts. For example, we may automatically evaluate information about your compensation and benefits to withhold taxes or determine your eligibility for employment or other benefits or other programs. You can find out more about the logic we use in our automated decision-making processes by contacting the Contact Persons.
In addition, we collect the following kinds of information about you from third parties:
- Information about your employment history and education: We collect information about your employment history and education during the interview and/or application process or when taking an employment action – such as considering you for a promotion or a new position at Footprint. We collect this information from your previous employers (or references provided by you) and the educational institutions you attended.
- Information about your professional certifications or licenses: We collect information about any professional certifications or licenses you might have from third parties to provide or verify those certifications or licenses.
- Information we collect from other employees and/or local, regional, or national governmental authorities (the “Authorities”). Other employees or Authorities may provide us with information about you, whether in the process of reporting an incident involving you, alerting us to an emergency situation involving you, or as part of the employment process. This information can include your name, information about your behavior or activities, and other information about the situation being reported to us.
- Background checks: We are required by our clients to conduct background checks on all prospective employees and contractors. These background checks are conducted by a third-party. These background checks include criminal background checks, motor vehicle and transportation checks, and checks on personal information. In addition, we are required to provide mandatory drug testing to all prospective employees and contractors. We will collect all such data and such data will be shared upon request in a generalized format and with any client of Footprint for whom the prospective employee or contractor will provide services.
- Immigration information: Governments and consulates may provide us with government identification, immigration information, or other information in order to facilitate travel related to services you provide to Footprint. The type of information provided may vary by country depending on applicable reporting requirements. For example, the Czech government may report information regarding criminal convictions and debts.
Purposes and Legal Basis for Processing Your Data
We may also be required to process your Personal Information to comply with laws applicable in the European Union or its member states.
You can obtain additional information about the processing we do to comply with applicable laws by contacting the Contact Persons.
In the case of Sensitive Personal Information (which includes information about your health, race, ethnicity, national origin, criminal convictions, religious or philosophical beliefs, sexual orientation, biometric data and trade union membership), we process information either (i) because we have your consent to do so or (ii) because we are required to process the information to comply with applicable laws or by our clients. For example, we are required to process sensitive data to comply with background checks that our clients require us to perform on anyone who will be rendering services, directly or indirectly, to such clients.
You can obtain more information about these laws by contacting the Contact Persons. When we process your Sensitive Personal Information on the basis of your consent, you may withdraw that consent at any time by contacting the Contact Persons. If you withdraw your consent, we may still be required to process your Sensitive Personal Information to comply with applicable law, but we will explain to you at the time your consent is withdrawn what processing activities will continue for legal compliance purposes.
Finally, we process your Personal Information for additional purposes that are compatible with those already described, including for the purposes of complying with our clients’ record keeping requirements. Where possible, we do not use identifiable information for these purposes, or we take steps, including making use of pseudonymous data, to limit the amount of Personal Information we use in our research or archives.
Recipients of Your Personal Information
Your Personal Information will be received and processed by Footprint employees and personnel, including third parties who provide services to Footprint. We share your Personal Information with our service providers or clients only when they have agreed to process your Personal Information only to provide services to us, or as part of internal compliance processes, and have agreed to protect your Personal Information from unauthorized use, access, or disclosure. You may contact us to learn more about the categories of service providers to whom your data is disclosed.
We may also disclose your contact information at Footprint in directories available to employees, and members of management of Footprint. You may request that your information be removed from this directory.
We also disclose your information to government authorities as required by laws that regulate immigration, tax, national security, and criminal activity.
Transfers to Third Countries
Footprint is a limited liability company headquartered in the United States. We transfer your data to the United States and to the countries where we operate, including, but not limited to, various countries which are members of the European Union and the United Kingdom. Data that is collected about you may be shared with our global headquarters in the United States and other global locations during the period of your employment.
Footprint has executed Standard Contractual Clauses, as approved by the European Commission. These clauses permit Footprint to transfer data from the EU to third countries, including the United States. If you would like to receive a copy of Footprint’ Standard Contractual Clauses, you can contact the Contact Persons.
We will retain your data throughout your period of employment and for a period of 5 years thereafter. We may be required by law to retain your information for a longer period. If you have any questions, you may contact the Contact Persons.
You have the right to the following information regarding Footprint’ processing of your Personal Information:
- the purposes of the processing,
- the categories of Personal Information concerned,
- the recipients or categories of recipients to whom the Personal Information have been or will be disclosed,
- where possible, the envisaged period for which the Personal Information will be stored, or, if not possible, the criteria used to determine that period.
This Data Privacy Notice is intended to provide this information. Any questions about these details may be directed to the Contact Persons.
You also have the following additional rights with respect to your Personal Information:
- The right to request access to the Personal Information that Footprint and/or third-party vendors utilized by Footprint have about you, as well as the right to request rectification of any data that is inaccurate or incomplete.
- The right to request a copy of your Personal Information in electronic format so that you can transmit the data to third parties, or to request that Footprint or such third-party vendors directly transfer your Personal Information to one or more third parties.
- The right to object to the processing of your Personal Information for marketing and other purposes.
- The right to erasure of your Personal Information when it is no longer needed for the purposes for which you provided it, as well as the right to restriction of processing of your Personal Information to certain limited purposes where erasure is not possible.
- The right to lodge a complaint with the appropriate supervisory authority where you believe that your rights have been violated.