Effective Date: January 21, 2020
Last Revised: January 8, 2020
This Policy is intended to comply with the General Data Protection Regulation (“GDPR”) as it applies to HR data. While we strive to cover the broadest range of our information processing activities globally, these processing activities may be more limited in some jurisdictions based on the restrictions of their laws. For example, the laws of a particular country or state may limit the types of personal information we can collect or the way we process that information. In those instances, we adjust our internal policies and practices to reflect the requirements of local law.
2. INTER-CON IS A GLOBAL CORPORATION HEADQUARTERED IN CALIFORNIA
Inter-Con is one of the largest security companies in the world, employing tens of thousands of individuals, not only throughout the United States, but also across twenty (20) countries and four (4) continents. A list of Inter-Con’s main offices is available at https://www.icsecurity.com/contact-us/ for reference. We are proud to boast a client list including federal, state, and local governments, multinational corporations, public utilities, and high net worth individuals. Above and beyond our commitment to security excellence, Inter-Con remains true to our roots. To this day, we remain 100% owned and managed by the family of Hank Hernandez, with our headquarters in Pasadena, California.
3. APPLICABILITY OF OTHER INTER-CON PRIVACY POLICIES
If you are unsure how or if this Policy applies to you, please contact Inter-Con at firstname.lastname@example.org or toll-free at +1 (800) 439-5550.
4. THIRD PARTY SERVICES
5. WHAT IS PERSONAL INFORMATION?
Before, during, or after your employment with Inter-Con, as required by law, we may have collected, or may need to collect, personal information. Your disclosure of personal information is voluntary, but please be aware that if you choose not to provide certain personal information, we may not be able to accomplish some of our employment and business objectives.
Personal information, also known as personally identifiable information or personal data, for purposes of this Policy is defined as any information that: (1) directly and clearly identifies an individual or (2) can be used in combination with other information to identify an individual (hereafter “Personal Information”). Examples of Personal Information include:
- ID numbers;
- home addresses;
- phone numbers;
- email addresses;
- names of family members; and
- date of birth.
6. WHAT IS SENSITIVE PERSONAL INFORMATION?
Sensitive Personal Information is a subset of Personal Information that may be more sensitive in nature for the individual concerned. Examples of sensitive Personal Information include:
- race and ethnic information;
- sexual orientation;
- political and religious beliefs;
- social security or other taxpayer/government-issued ID numbers;
- financial information;
- health or medical information;
- criminal records; and
- in some regions, such as the European Union, trade union membership.
7. WHAT PERSONAL INFORMATION DO WE COLLECT?
We collect and maintain different types of Personal Information about you in accordance with applicable law. Some examples include:
- name, gender, home address, telephone number, date of birth, marital status, employee identification number, and emergency contacts;
- residency and work permit status, military status, and nationality and passport information;
- social security or other taxpayer/government identification number;
- payroll information and banking details;
- wage and benefit information;
- retirement account information;
- sick pay, paid time off, retirement accounts, pensions, insurance, and other benefits information (including the gender, age, nationality, and passport information for any spouse, minor children, or other eligible dependents and beneficiaries);
- information from interviews and phone screenings you may have had;
- date of hire, date(s) of promotion(s), work history, technical skills, educational background, professional certifications and registrations, language capabilities, and training records;
- employee stock information;
- beneficiary and emergency contact information;
- forms and information relating to the application for, or in respect of changes to, employee health and welfare benefits (including short- and long-term disability, medical and dental care, etc.);
- height, weight, and clothing sizes, photographs, videos, physical limitations, and special needs;
- records of work absences, vacation/paid time off, entitlement and requests, salary history and expectations, performance appraisals, letters of appreciation and commendation, and disciplinary and grievance procedures (including monitoring compliance with and enforcing our policies);
- where permitted by law and applicable, we may collect the results of credit and criminal background checks, the results of drug and alcohol testing, screening, health certifications, driving license number, vehicle registration, and driving history;
- information required for us to comply with laws, the requests and direction of law enforcement authorities or court orders (e.g., child support and debt payment information);
- acknowledgement regarding our policies, including employee handbooks, ethics and/or conflicts of interest policies, and computer and other corporate resource usage policies;
- information captured on security systems and global positioning devices, including closed circuit television, key card entry systems, and Inter-Con-issued devices and affiliated applications (e.g., Salesforce);
- voicemails, emails, correspondence, documents, and other work product and communications created, stored, or transmitted using our networks, applications, devices, computers, or communications equipment;
- date of resignation or termination, reason for resignation or termination, information relating to or administering termination of employment (e.g., references);
- letters of offer and acceptance of employment;
- your resume/CV, cover letter, previous and/or relevant work experience or other experience, education, transcripts, or other information you provide to us in support of an application and/or the application and recruitment process;
- references and interview notes; and
- information relating to any previous applications you may have made to Inter-Con and/or any previous employment history with Inter-Con.
8. HOW IS YOUR PERSONAL INFORMATION COLLECTED?
Generally, we collect Personal Information directly from you in circumstances where you provide Personal Information (e.g., during the onboarding process, signing up for direct deposit, and enrolling in benefits or services). However, in some instances, the Personal Information we collected has been inferred about you based on other information you provide us, through your interactions with us, or from third parties. When we collect your Personal Information from third parties, it is either because you have given us express permission to do so, your permission was implied by your actions (e.g., your use of a third-party employee service made available to you by us), or because you provided explicit or implicit permission to the third party to provide the Personal Information to us.
When permitted or required by applicable law or regulatory requirements, we may collect Personal Information about you without your knowledge or consent. We further reserve the right to monitor the use of our premises, equipment, devices, computers, network, applications, software, and similar assets and resources. In the event such monitoring occurs, it may result in the collection of Personal Information about you.
9. HOW WE USE THE PERSONAL INFORMATION WE COLLECT
Inter-Con may use your Personal Information in order to:
- manage all aspects of an employee’s employment relationship including, but not limited to, the establishment, maintenance, and termination of employment relationships (e.g., determining eligibility for initial employment, including the verifications of references and qualifications); pay and benefits administration; issuance and management of stock options and restricted stock units if any; corporate travel and other reimbursable expenses; development and training; absence monitoring; project management; auditing, compliance, and risk management activities; career management, including the assessment of qualifications for a particular job or task; processing employee work-related claims (e.g., workers’ compensation and insurance claims); succession planning; relocation assistance; obtaining and maintaining insurance; provisions of employee-related services; and other general operations, administrative, financial, and human resources related purposes;
- assist you with obtaining an immigration visa or work permit where required;
- use in video conferencing;
- maintain directories of employees;
- implement employee engagement programs (e.g., surveys);
- administer our occupational safety and health programs;
- protect the safety and security of our workforce, guests, property, and assets (including controlling and facilitating access to and monitoring activity on and in our premises and activity using our computers, devices, networks, communications, and other assets and resources);
- investigate and respond to claims against us;
- maintain emergency contact and beneficiary details;
- comply with applicable laws (e.g., health and safety, employment laws, office of foreign asset controls regulations, and tax laws), including judicial or administrative orders regarding individual employees (e.g., garnishments and child support payments);
- execute any additional purposes that we advise you of (if applicable law requires your express consent for such additional use or disclosure, we will obtain it from you); and
- execute other purposes as part of our business activities when reasonably required by us.
10. SHARING PERSONAL INFORMATION
Your Personal Information may be shared, including to our affiliates, subsidiaries, and other third parties, as follows:
- where you request us or provide your consent to us;
- in order to carry out the uses of Personal Information as described above (see Paragraph 9 above);
- when using or collaborating with third parties in the operation of our business, including in connection with providing many of the benefits and services we offer our employees (e.g., Human Resources Information Systems, Financial Investment services providers, wellness program services providers, insurance providers, etc.);
- if we buy or sell businesses and other assets;
- where required by law, by order or requirement of a court, administrative agency, or government tribunal, which includes in response to a lawful request by public authorities, including to meet national security or law enforcement requirements or in response to legal process;
- if we determine it is necessary or desirable to comply with the law or to protect or defend our rights to property;
- as necessary to protect the rights, privacy, safety, or property of an identifiable person or group or to detect, prevent, or otherwise address fraud, security, or technical issues, or to protect against harm to the rights, property, or safety of Inter-Con, our users, applicants, candidates, employees, or the public, or as otherwise required by law;
- where the Personal Information is public;
- to seek advice from our lawyers and other professional advisers; and
- to aid professional advisers (e.g., bankers, lawyers, and accountants) and potential buyers and vendors in connection with the disposal or acquisition by use of a business or assets.
Like most international businesses, we have centralized certain aspects of our business operations, including for example, financial, human resources, and information technology administration. This may result in the transfer of Personal Information from country to another and amongst our various subsidiaries and affiliates. It should be noted that this may or may not include countries where the level of privacy protection and the legal rights of individuals are not considered commensurate with standards of protection in jurisdictions having comprehensive data protection laws, such as the countries of the European Union and Canada.
11. ACCESS TO PERSONAL INFORMATION WE COLLECT
When requesting access to your Personal Information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the Personal Information that we hold about you. We will delete the information you provide us for verification purposes once your request has been answered.
Please note your right to access the Personal Information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or requires us to refuse to provide some or all the Personal Information that we hold about you. In addition, the Personal Information may have been destroyed, erased, or made anonymous. If we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
12. CORRECTION OF COLLECTED PERSONAL INFORMATION
We strive to ensure that Personal Information in our possession is accurate, current, and complete. If an individual believes that the Personal Information about him or her is incorrect, incomplete, or outdated, he or she may request the revision or correction of that information by contacting us at email@example.com or toll-free at +1 (800) 439-5550. We reserve the right not to change any Personal Information we consider is accurate.
If it is determined that Personal Information is inaccurate, incomplete, or outdated, we will use reasonable efforts to revise it and, if necessary, use reasonable efforts to inform agents, service providers, or other third parties, which were provided with inaccurate information, so records in their possession may be corrected or updated.
13. RETENTION OF COLLECTED PERSONAL INFORMATION
Except as otherwise permitted or required by applicable law or regulatory requirements, we will retain your Personal Information only for as long as we believe it is necessary to fulfill the purposes for which the Personal Information was collected (including, for the purpose of meeting any legal, accounting, or other reporting requirements or obligations).
You may request that we delete the Personal Information about you that we hold by contacting us at firstname.lastname@example.org or toll-free at +1 (800) 439-5550. There are instances where applicable law or regulatory requirements allow or require us to refuse to delete this Personal Information. In the event we cannot delete your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
14. WITHDRAWAL OF CONSENT
In certain circumstances, you may have provided express consent in connection with your providing certain Personal Information to us of for a specific use of your Personal Information. In certain countries and/or jurisdictions, you may have a right to withdraw that consent. Please contact us at email@example.com or toll-free at +1 (800) 439-5550 for further information or instructions.
This Policy is reviewed periodically to ensure it accurate captures all types of data collected or any additional or different processing of such data. We may, therefore, change this Policy at any time. The effective date of each version of this Policy is identified above.
16. SECURITY OF COLLECTED PERSONAL INFORMATION
We are committed to protecting the security of the Personal Information collected, and we take reasonable physical, electronic, and administrative safeguards to help protect the information from unauthorized or inappropriate access or use.
17. PRIVACY SHIELD
With respect to the Personal Information of our employees, Inter-Con complies with the EU-U.S. and Swiss-U.S. Privacy Shield Framework and adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, visit https://www.privacyshield.gov/.
In compliance with the Privacy Shield Principles, Inter-Con is committed to resolving complaints or concerns you may have about privacy or how your Personal Information is used. If your complaint is not satisfactorily resolved with us directly, you may contact our independent dispute resolution provider, the International Centre for Dispute Resolution/American Arbitration Association for resolution (http://go.adr.org/privacyshield.html).
Inter-Con is subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to the Privacy Shield. Under certain conditions, you may invoke binding arbitration before the Privacy Shield Panel. Where applicable for employee matters, Inter-Con commits to cooperation with the panel of the EU Data Protection Authorities, the state or national data protection authority where the employee works, or the Swiss Federal Data Protection and Information Commissioner, as applicable, to investigate unresolved complaints.
Notwithstanding any language to the contrary in this Policy, in cases of onward transfer to third parties of Personal Information of individuals received pursuant to the EU-U.S. and Swiss-U.S. Privacy Shield, Inter-Con is potentially liable.
18. CONTACT US
If you have questions or concerns regarding the handling of your Personal Information, or would like to report potential data breaches involving Personal Information, please contact us at firstname.lastname@example.org or toll-free at +1 (800) 439-5550. Our corporate headquarters is located at:
Inter-Con Security Systems, Inc.
210 South De Lacey Avenue
Pasadena, California 91105
United States of America