PERSONNEL PRIVACY POLICY
Effective Date: December 20, 2024
Introduction
Sartori Company (“Sartori”) respects personnel privacy and is committed to protecting the personal information it obtains and maintains from current, former, and prospective employees. Sartori maintains this Personnel Privacy Policy in compliance with the California Consumer Privacy Act (“CCPA”). Sartori does not “sell” or “share” your personal information.
Scope
This policy applies solely to applicants, employees, directors, officers, owners, and independent contractors of Sartori that are California residents (“Personnel”). This policy does not apply to personal information outside the scope of the CCPA, such as personal information that is collected or used in accordance with the Gramm-Leach-Bliley Act, the California Financial Information Privacy Act, the Fair Credit Reporting Act, the Confidentiality of Medical Information Act, or the Health Insurance Portability and Accountability Act (“HIPAA”). This policy also does not apply to information that is publicly available through government records.
Collection of Personnel Information
The below chart lists the categories of personnel personal information that Sartori may collect and has collected in the past 12 months, as permitted by applicable laws, and with whom Sartori discloses such information.
| Categories of Personal Information | Categories of Services Providers and Third Parties with Whom Personal Information is Disclosed |
|---|---|
| Identifiers. This may include name, home address, telephone number, date of birth, Social Security Number, driver’s license number, passport number, internet protocol address, email address, or online identifier. | Entities that Sartori is required to share with pursuant to law or for legal proceedings; service providers; Sartori’s affiliates; Sartori’s customers and prospective customers; prospective purchasers of our business; and outside auditors and lawyers. |
| Protected classification information. This may include residency and work permit status, race, gender, and ethnicity. | Entities that Sartori is required to share with pursuant to law or for legal proceedings; service providers; and Sartori’s affiliates. |
| Professional or employment related information. This may include date of hire, date(s) of promotion(s), work history, technical skills, educational background, professional certifications, licensing and registrations, language capabilities, training courses attended, records of work absences, salary history and expectations, performance appraisals, letters of appreciation and commendation, and disciplinary and grievance procedures. | Entities that Sartori is required to share with pursuant to law or for legal proceedings; service providers; Sartori’s affiliates; Sartori’s customers and prospective customers; prospective purchasers of our business; and outside auditors and lawyers. |
| Banking or financial details. This may include your financial information which is necessary to pay you, such as the name of your bank and account routing information. | Entities that Sartori is required to share with pursuant to law or for legal proceedings; service providers; and Sartori’s affiliates. |
| Benefits information. This may include information related to sick pay, pensions, and insurance. | Entities that Sartori is required to share with pursuant to law or for legal proceedings; service providers; Sartori’s affiliates; and outside auditors and lawyers. |
| Employment eligibility information. This may include the results of criminal background checks, civil background checks, educational background information, the results of drug and alcohol testing, COVID-19 vaccination status, audio testing, screening, health certifications, driving license number, vehicle registration, and driving history. | Employment eligibility information. This may include the results of criminal background checks, civil background checks, educational background information, the results of drug and alcohol testing, COVID-19 vaccination status, audio testing, screening, health certifications, driving license number, vehicle registration, and driving history. Entities that Sartori is required to share with pursuant to law or for legal proceedings; service providers; and Sartori’s affiliates. Vaccination status may also be shared with Sartori’s customers. |
| Legally required information. This may include child support and debt payment information. | Entities that Sartori is required to share with pursuant to law or for legal proceedings; and service providers. |
| Inferences drawn about you based on other personal information you provide. This may include your preferences, characteristics, behavior, attitudes, intelligence, and abilities. | Service providers and Sartori’s affiliates. |
| Automatically collected security information. This may include information captured on security systems, including CCTV and key card entry systems. | Entities that Sartori is required to share with pursuant to law or for legal proceedings; service providers; and Sartori’s affiliates. |
| Communications. This may include voicemails, e-mails, SMS/texting, correspondence and other work product and communications created, stored or transmitted by an employee using Sartori’s computer or communications equipment. | Entities that Sartori is required to share with pursuant to law or for legal proceedings; service providers; Sartori’s affiliates; and Sartori’s customers and prospective customers. |
Sources From Which Personal Information is Collected
Sartori may collect personal information from the following sources: you; service providers; Sartori’s affiliates; financial institutions; publicly available resources; other Sartori employees; government entities or regulators; legally interested third parties; and Sartori’s customers.
How Sartori Uses Personal Information
Sartori may use Personnel personal information in the following ways:
· To evaluate an application for employment;
· To conduct employee surveys;
· To conduct business (including serving Sartori’s customers and marketing);
· To comply with legal obligations;
· For employee management and administration;
· For employment verification;
· To administer benefits;
· For fraud prevention or other internal investigations;
· To administer payroll;
· To address employee relations issues; or
· To maintain, monitor, and improve Sartori’s information systems and networks.
Retention Period
Sartori retains the information listed above in accordance with its data retention policies or as otherwise may be required by law.
Covered Personnel Rights
The CCPA provides Personnel with the following specific rights regarding their personal information in certain circumstances:
o The right to request that Sartori disclose the following information about Sartori’s collection and use of your personal information:
o The categories of personal information Sartori collected about you;
o The categories of sources of the personal information Sartori collected about you;
o Sartori’s business purpose for collecting that personal information;
o The categories of third parties with whom Sartori shares that personal information; or
o The specific pieces of personal information Sartori collected about you.
o The right to delete personal information that Sartori has collected about you.
o The right to correct inaccurate personal information that Sartori maintains about you.
o The right to not receive discriminatory treatment by Sartori for the exercise of privacy rights conferred by the CCPA including your right to not be retaliated against for exercising your CCPA rights.
Please note the above rights are subject to certain exceptions.
Exercising Personnel Rights
To exercise your rights described above, please submit a verifiable request to Sartori by sending an email to cadleman@sartoricheese.com.
We will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. If you are using an authorized agent, please note that you will be required to verify your identity and provide written confirmation that you have authorized the agent to make a request on your behalf. For requests to access or delete, we may require you to verify your identity directly with us, and directly confirm with us that you provided the authorized agent permission to submit the request. Sartori will respond to most requests within 45 days, or otherwise request an additional 45-day period within which to respond.
Contact
For questions or complaints regarding this Personnel Privacy Policy, please contact Human Resources.
Policy History/Revision Dates
Origination Date: 12/20/2024
Last Amended Date: 12/20/2024
Next Review Date: 12/2025