California Workforce Privacy Notice

Scope and Overview

This Workforce Privacy Notice (“Privacy Notice”) describes how WoodmenLife and its subsidiaries and affiliates (collectively, “WoodmenLife”, “we”, “our” or “us”) collects, uses, shares, and protects personal information. This Notice also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions.

This Privacy Notice applies to all current and former employees, workers, independent contractors, and any other individuals who are working for WoodmenLife but are not directly employed (collectively, “workforce member(s)” or “you”).

Please read this Privacy Notice carefully. If you have any questions or need to access this Privacy Notice in an alternative format due to having a disability, please contact WoodmenLife at 1-800-225-3108 or 1700 Farnam St., Omaha, NE 68102.

This Privacy Notice covers:

Personal Information We Collect
How We Collect Your Personal Information
How We Process Your Personal Information
How We Share Your Personal Information
How Long We Retain Your Personal Information
How We Protect Your Personal Information
Your Choices
Changes to this Privacy Notice
Contact Information
Additional Information for California Residents

1. Personal Information We Collect

To carry out our business activities and obligations, we collect, store, and process different types of personal information, some of which we require to administer the employment or other working relationship with you. The following provides examples of the categories of personal information we may collect and how we process such information.

Context	Types of Data	Primary Purpose for Collection and Use of Data
Identification Information	Name, date of birth, employee identification number, sales identification number, government-issued identification number (e.g., driver’s license number, state identification card, passport, national identification number, Native American tribal document, birth certificate, social security number, etc.), residency and work permit status, and other similar documents used to verify work eligibility.	We process this type of information for our business purposes, including general human resources and sales administration and to comply with legal obligations, such as employment or insurance representative eligibility verification laws.
Contact Information	Home address, telephone number(s), e-mail address(es), beneficiary and emergency contact details, and other similar contact information.	We process this type of information to fulfil our obligations to you, including managing our employment or working relationship with you (e.g., communicating with you.) We also process this type of information for our business purposes, such as to assist you in the case of an emergency, including maintenance of contact details for you, and your dependents or emergency contacts in the case of a personal or business emergency.
Payroll and Taxes	Rate of pay, commissions, salary, bonuses, bank account details, tax status and withholding information (i.e., marital status, dependents, etc.), social security number or other taxpayer/government identification number, and other information necessary to administer payroll and taxes.	We process this type of information to fulfil our obligations to you, including administering payroll and benefits, making expense reimbursements and other compensation-related payments, and tax reporting.
Benefits Related Information	Spouse, beneficiary, and dependents information, retirement account information, paid and unpaid leaves of absence, and other information necessary to administer benefits.	We process this type of information to fulfil our obligations to you, including administering and maintaining benefits, such as medical dental, optical, additional wellness programs, 401(k) and/or retirement plans and additional fringe benefit programs, including recording and processing eligibility of dependents, absence and leave monitoring, and insurance.
Health Related Information	Information about job-related medical conditions that impact your ability to perform your job with or without a reasonable accommodation, and health and sickness related information related to reasons for time away from work.	We process this type of information for our business purposes (where permissible and in accordance with applicable law), including scertaining your fitness to perform your job duties with or without a reasonable accommodation, managing absences from work, and complying with legal obligations related to health and safety.
Demographic Data	Please note, under federal and some local laws, we are required to collect and report certain demographic workforce data to federal, state and or local government agencies for civil rights enforcement purposes. This may include date of birth and gender as well as more sensitive personal information including information relating to racial and ethnic origin, religious, political, or philosophical beliefs, and trade union membership. We may also ask you to voluntarily self-identify whether you belong to additional protected classes (disability status, sexual orientation, veteran status, etc.), to promote diversity, equity, and inclusion within the company.	In some jurisdictions, we are required to collect and report certain demographic workforce data to federal, state and or local government agencies. We also process this type of information for our business purposes (where permissible and in accordance with applicable law), including promoting diversity, equity, and inclusion within the company.
Recruitment	Educational and professional background information, such as academic and professional qualifications, education, CV/Resume, reference letters, interview notes, credit history and criminal records data (utilized for background check and vetting purposes where permissible and in accordance with applicable law).	We process this type of information for our business purposes, including determining eligibility for hiring, verifying references and qualifications, and making business decisions about your recruitment or employment. We also process this type of information to fulfil our obligations to you, including general human resources administration and business management.
Terms of Employment	Employment details, such as your job titles/position, office location, letters of offer and acceptance of employment, and/or employment agreements or other working arrangements, hire/re-hire date, termination date, performance history, disciplinary information, professional memberships, and business travel arrangements, leave of absence, sick time, and vacation/holiday records.	We process this type of information to fulfil our obligations to you, including managing our employment or working relationship with you, conducting performance reviews, managing and determining performance requirements, making decisions about salary reviews and compensation, assessing qualifications for a particular job or task, including decisions about promotions, making decisions about your continued employment or engagement. We also process this type of information for our business purposes, including general business management and operations, accounting, and auditing.
Qualifications and Training	We collect information from individuals concerning the training that they receive from us, or from third parties. Where applicable, we also collect information related to licensing and certifications.	We process this type of information for our business purposes, including establishing training and/or development requirements, understanding and recording qualifications of the individuals that work with us, and in some cases complying with any statutory, regulatory, or contractual obligation regarding the training or qualification of certain staff.
Investigations	Details of any workplace investigations.	We process this type of information for our business purposes, including ensuring a safe working environment, investigating all information related to potential violations of workplace policies, procedures, protocols, concerns, and/or complaints.
IT and Communications Information	Information about your use of our information technology (IT) and communications systems. For more information about what we monitor and why, please refer to the WoodmenLife Information Security: Acceptable Use Policy.	We process this type of information for our business purposes (where permissible and in accordance with applicable law), including managing network and IT systems security, monitoring the use of our IT and communication systems, ensuring compliance with our internal policies and procedures, protecting confidential information, intellectual property, and other business interests, and investigating unlawful or improper acts.
Video, Voice and Images	Audio visual information, such as photographs, video images like closed-circuit television (“CCTV”), call monitoring records, and voicemails.	We process this type of information for our legitimate business purposes (where permissible and in accordance with applicable law), including compiling and maintaining internal directories (such as directories of employees and staff), securing our facilities and equipment, and protecting our property.

2. How We Collect Your Personal Information

Most often, we collect personal information from you directly, including through the application and recruitment process as well as in the course of your employment or working relationship with us.

In some cases, we also collect personal information about you from third parties, such as employment agencies, former employers, and personal and professional references, or public sources. For example, before and during the course of your employment or working relationship with us, we may collect information from public social media sources, such as your LinkedIn profile, for recruitment purposes. We may also conduct lawful background screenings, to the extent permitted by law, through a third-party vendor for information about your past education, employment, credit and/or criminal history. Before we conduct a background check, we will provide you with acknowledgement and authorization forms. Additionally, if there is an investigation of a workforce matter, we may obtain information relevant to the incident from external sources including private parties and/or law enforcement.

We will also collect additional personal information in the course of job-related activities. This may include monitoring communications and use of Woodmen Life IT equipment and systems, or from other staff members or supervisors.For more information about what we monitor and why, please refer to the WoodmenLife Information Security: Acceptable Use Policy.

3. How We Process Your Personal Information

In addition to the purposes and uses described elsewhere in this Privacy Notice, we may process your personal information for the following legitimate business purposes and for the purposes of performing the employment contract with you:

To manage your employment or other working relationship with us, including payroll and benefits administration, business management and planning, processing employee work-related claims (for example, insurance and worker's compensation claims); accounting and auditing, conducting performance reviews and determining performance requirements, and assessing qualifications for a particular job or task.
To comply with applicable legal and regulatory obligations, including those related to labor and employment, health and safety, tax, and anti-discrimination laws.
To ensure a safe working environment, including investigating potential misconduct.
To protect health and safety in the workplace.
To detect and protect against malicious, deceptive, fraudulent, or illegal activity, violations of our policies, or other types of wrongdoing.
To enforce, exercise, or defend legal claims, and enforce disciplinary actions or termination.
To ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution. This may include monitoring communications and use of Woodmen Life IT equipment and systems (where permitted by, and in accordance with, applicable law).
To conduct data analytics analyses to review and better understand employee retention and attrition rates.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
For other lawful or legitimate purposes which may be reasonable to plan, organize, and carry out administrative tasks required for day-to-day operations.

4. How We Share Your Personal Information

In addition to the specific situations discussed elsewhere in this Privacy Notice, we share your personal information in the following situations,where permitted or required by applicable law:

Affiliates. We share your information with our subsidiaries and affiliates in the course of our normal business operations.
Business Transactions. We may share your information with a potential buyer (and its agents and advisors) in connection with any proposed merger, acquisition, or any form of sale or transfer of some or all of our assets (including in the event of a reorganization, dissolution, or liquidation), in which case, personal information held by us about you will be among the assets transferred to the buyer or acquirer.
Other Workforce Members.Other individuals within the company may have access to your information. For instance, all workforce members can access phone and electronic directories. Depending upon the type of processing and its purposes, your personal information may be shared with workforce members within the Human Resources, Finance or IT Department, workforce members in charge of the security of our facilities, your supervisor, and your supervisor’s supervisor.
Service Providers. We share your information with our contractors, vendors, and service providersthat assist us with administering the employment or working relationship with you and/or provide services to us or on our behalf. For example, service providers may include, but are not limited to, payroll processors, benefits administration providers, data storage or hosting providers, marketing/events agencies, and recruitment agencies.
Other Third Parties. We may share certain information with third parties who provide professional services (such asattorneys, auditors, accountants, and management consultants), professional bodies, and regulatory authorities in the normal course of business.
Legal or Regulatory Requests and Investigations.We may disclose your information to third parties under the following circumstances (i) to comply with relevant laws or regulations, to respond to a court order, administrative or judicial process, such as a subpoena, warrant, court order, or government audit; (ii) in response to lawful requests by public authorities (such as national security or law enforcement); and (iii) as necessary to establish, exercise or defend against potential, threatened or actual litigation (such as adverse parties in litigation). We may also need to share your information with tax authorities, courts, regulators, the police, and other governmental authorities where we are required or permitted to do so by law.
Protection of the Company or Others. We may share your information where necessary to protect the company, including to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.
Disclosures with Your Consent. We may ask to share your information with other unaffiliated third parties who are not described elsewhere in this Privacy Notice. For example, we may share your information with third parties to whom you or your representatives authorize us to disclose personal information in connection with products or services we or they provide to you.

5. How Long We Retain Your Personal Information

Except as otherwise permitted or required by applicable law or regulation, we endeavour to retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes.To determine the appropriate retention period for personal information, we consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, and the purposes for which we process your personal information.

6. How We Protect Your Personal Information

We maintain reasonable physical, technical, and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to help protect your personal information against loss, unauthorized access or disclosure, modification, or destruction. While we use reasonable efforts to protect your personal information, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any privacy or security event relating to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

7. Your Choices

Some jurisdictions give you the right to make the following choices regarding your personal information:

Request access to and obtain a copy of the personal information we have about you, including certain information about how we process your personal information;
Request correction (or rectification) of any inaccurate or incomplete personal information we have about you; and
Request erasure (or deletion) of your personal information, subject to certain limitations and exceptions.
Request to opt-out of the sale or sharing of your personal information, subject to certain limitations and exceptions.

Please note, not all these rights are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your requests to access, modify, or delete your information, or to revoke consent or object to processing. This may occur because the law permits or requires us to do so.

If you want to exercise any of the above rights, please visit woodmenlife.org and select “Privacy Requests” located at the bottom of the page or call 1-800-542-9756. We do not discriminate against individuals that exercise state-conferred rights. Please note that in order to fulfill your request, we may need you to provide certain personal information to verify your identity. We may verify your identity in person, by phone call, or via email. Depending on your request, we will ask for information such as your name, your employee ID, or the name of your direct supervisor. We may also ask you to provide a copy of your government-issued identification.

If you are a California resident, you may designate an authorized agent to submit a request on your behalf to access, correct, or delete your personal information. To do so, you must (1) provide that authorized agent written, signed, and notarized permission to submit such request, and (2) verify your own identity directly with us.

If you are submitting a request on behalf of another person, please visit woodmenlife.org and select “Privacy Requests” located at the bottom of the page or call 1-800-542-9756. You must provide written and notarized proof that you have been authorized by the individual to act on his or her behalf. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized to submit such request.

8. Changes to this Privacy Notice

We may update or change this Privacy Notice from time to time. You can see when this Privacy Notice was last updated by referring to the date at the end of this Privacy Notice. To the extent we make material changes, the Privacy Notice that was in place at the time you submitted personal information to us will generally govern that information.

9. Contact Information

If you have any questions about this Privacy Notice, would like additional information, or make a request to exercise any of your rights, please visit woodmenlife.org and select “Privacy Requests” located at the bottom of the page or call 1-800-542-9756.

10. Additional Information

California law requires us to disclose the following additional information related to our privacy practices. If you are a California resident, this section applies to you in addition to the rest of this Privacy Notice:

Categories of Personal Information Collected and Disclosed

California law requires organizations to disclose whether certain categories of personal information are collected, disclosed for an organization’s “business purpose”, “sold,” or “shared” for purposes of cross-context behavioral advertising (as those terms are defined under California law). The following describes the categories of personal information we collect and to whom we disclose such information for business purposes. We do not “sell” or “share” personal information for purpose of cross-context behavioral advertising about workforce members (as such terms are defined under California law).

Categories of Personal Information	Disclosures for a Business Purposes
Identifiers, such as real name, social security number, driver’s license number, state identification number or passport number, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers.	Affiliates or subsidiaries Business partners Government entities (as may be needed to comply with law or prevent illegal activity) Internet service providers Operating systems and platforms Other Service Providers
Other identifying information, such as physical characteristics or description, date of birth and signature.	Affiliates or subsidiaries Business partners Government entities (as may be needed to comply with law or prevent illegal activity) Other Service Providers
Financial information, such as banking details, tax information, payroll information, and withholdings.	Affiliates or subsidiaries Business partners Government entities (as may be needed to comply with law or prevent illegal activity) Other Service Providers
Health and safety information, such as health conditions (if relevant to your employment), job restrictions, workplace illness and injury information, and health insurance policy information.	Affiliates or subsidiaries Government entities (as may be needed to comply with law or prevent illegal activity) Other Service Providers
Characteristics of protected classifications under California or federal law, such as age, race, color, 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, veteran or military status to the extent disclosed by the workforce member.	Affiliates or subsidiaries Government entities (as may be needed to comply with law or prevent illegal activity) Other Service Providers
Internet or other electronic network activity information, such as your search history, browsing history, login information, and IP addresses on company information systems and networks.	Affiliates or subsidiaries Government entities (as may be needed to comply with law or prevent illegal activity) Internet service providers Other Service Providers
Geolocation data, such as time and physical location related to use of an internet website, application, device, or physical access to a company office location.	Affiliates or subsidiaries Government entities (as may be needed to comply with law or prevent illegal activity) Internet service providers Other Service Providers
Sensory information, such as audio, electronic, visual, thermal, olfactory, or similar information. This may include call monitoring and video surveillance and in some cases COVID-19 or other public health related temperature checks.	Affiliates or subsidiaries Government entities (as may be needed to comply with law or prevent illegal activity) Other Service Providers
Professional or employment-related information, such as work history, academic and professional qualifications, educational records, references, interview notes, job title, position, hire dates, compensation, performance and disciplinary records, and vacation and sick leave records.	Affiliates or subsidiaries Business partners Government entities (as may be needed to comply with law or prevent illegal activity) Other Service Providers
Inferences drawn from any of the information listed above, such as profile or summary about a workforce member's preferences, characteristics, attitudes, intelligence, abilities, and aptitudes.	Affiliates or subsidiaries Government entities (as may be needed to comply with law or prevent illegal activity) Business partners Other Service Providers

Sensitive Information Disclosure

Some of the personal information we collect as described above is considered “sensitive personal information” under California law. We may collect the following categories of sensitive personal information (as defined under California law): Social security, driver’s license, state identification card, or passport number; racial or ethnic origin, religious, or philosophical beliefs, or union membership; contents of a workforce member’s mail, email, and text messages unless the business is the intended recipient of the communication; ; and information concerning health; and information concerning sex life or sexual orientation. This information is collected in order to administer your relationship with us, including fulfilling any obligation that we have to provide you with compensation and/or benefits; determine eligibility for employment; conduct background checks (where permitted by applicable law); comply with applicable laws and regulations; create, maintain, and secure online employee accounts; business travel; manage and monitor employee access to Company facilities, equipment, and systems; investigate and enforce compliance with and potential breaches of the Company’s internal policies and procedures; and exercise or defend the legal rights of the Company and its employees and affiliates, customers, contractors, and agents. Note that we do not use such information for any purposes that are not identified within the California Privacy Rights Act Section 1798.121. We do not “sell” or “share” sensitive personal information for purposes of cross-context behavioral advertising.

Effective Date. December 29, 2022

Last Updated Date. December 29, 2022

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