Applicant Privacy Policy

Lactalis Employee and Applicant Privacy Policy

Last Updated: December 22, 2022

PURPOSE

The purpose of this Employee and Applicant Privacy Policy (this “Policy”) is to set out how Lactalis Heritage Dairy, Inc., and Lactalis American Group, Inc., its subsidiaries and affiliates, including, Karoun Dairies, LLC., and Central Valley Cheese, Inc., and Lactalis US Yogurt, Inc. (“us,” “our,” or “we”) collect, use, store, or otherwise process personal information about our employees, contractors, job applicants and/or candidates (collectively, “you”), including when you access or use our careers websites, e.g.,  Paylocity for Current and Former Employees, Lactalis Heritage Dairy Careers Page, Lactalis American Group Careers Page, and Lactalis US Yogurt Careers Page, and the rights to which you are afforded.

SCOPE

This Policy does not cover your use of our products or services as a consumer (for more information, please read our website Privacy Policy at https://lactalisheritagedairy.com/privacy-policy/, or to any third-party websites and apps that you may use, including those to which we link in our websites. You should review the terms and policies for third-party websites and apps before clicking on any links.

 

READ THIS POLICY CAREFULLY

We recommend that you read this Policy in full to ensure you are fully informed about the manner in which we collect, use, store, disclose, transfer or otherwise process your personal information as well as your privacy rights.

 

WHAT INFORMATION WE COLLECT & FROM WHOM DO WE COLLECT IT

Subject to applicable law, we process your personal information for business purposes, including those related directly to and recruiting job applicants and/or candidates, fulfilling open job positions and your employment with us.

 

Personal Information We Collect from You. Subject to applicable law, we may collect the following categories of personal information from you through the application and recruitment process and while you conduct work for us:

 

• Identifiers and contact information. This includes your name, date of birth, email address, mailing address, phone number, photograph, work and personal references and contact details, beneficiary and emergency contact details, and other similar contact data.

 

• National identifiers and work eligibility information. This includes your national identification number, social security number, passport details, social insurance number, government identification number, country, region, and city of birth, nationality, citizenship status, visa status, residency and work permit status, and immigration information.

 

• Demographic information. This includes your age, income, race, ethnicity, marital/civil partnership status, gender, sexual orientation, and military service. 

 

• Employment history and background check information. This includes your resume, Curriculum Vitae, work history, professional background, third party references, and, where applicable and allowed by applicable law, information associated with social media platforms (e.g., social media handle) or professional networking sites (e.g., LinkedIn profile) credit history, criminal records, and other information revealed during background screenings.

 

• Educational information. This includes your educational history, academic degrees, and qualifications, certifications, and skills.

 

• Professional or employment-related information.  This includes your date of birth, gender, veteran status, marital status and details of dependents, next of kin and emergency contact information, beneficiaries, your bank account details, payroll records and tax status information, your alary, annual leave, pension and benefits information, if your role involves driving, a copy of your driving license, your current employment records (including job titles, work history, working hours, place of work, start date, training records, qualifications and professional memberships and professional body membership numbers), history of pay, bonus, and other benefits, the details of your performance and appraisals, where applicable, disciplinary and grievance information, details of any payments made on termination, information about your health, including any medical condition, health and sickness records.

 

• Sensitive personal information. This includes information requiring special handling related to racial and ethnic origin, religious beliefs, sexual orientation, religious beliefs, trade union membership, criminal offenses or convictions, and health and medical information, including disability status, where we have obtained your consent or the collection of such data is allowed by applicable law.

 

• Videos.  To ensure the safety and security of our customers, associates and assets, closed circuit television and cameras are used throughout our facilities. These cameras are used for purposes such as safety and security, asset protection, operations improvement, and deterrence and investigation of misconduct. Cameras will only be used in areas where an individual has an expectation that the individual could be recorded.

 

• Equipment and System Monitoring.  We reserve the right to monitor the 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 information about you. If required by applicable law, we will notify you of such monitoring and obtain your consent. We also use email filters to block spam and computer viruses. These filters may from time-to-time block legitimate email messages. We also collect other information obtained through electronic means such as swipe card and badge records. 

 

• Other Information. Any other information you voluntarily submit to us in connection with your application for employment (e.g., compensation history), including that which you provide via webform, during an interview, or as part of other forms of assessment.

Personal Information We Collect from Other Sources. Subject to applicable law, we may collect personal information about you from others, such as:

• Third-Party Sources. Examples of third-party sources include employment screening agencies, background check agencies, recruiting agencies, service providers, former employers and/or schools and educational institutions, publicly available information on websites or social media (e.g., when applying through LinkedIn, where relevant for recruitment purposes and allowed by applicable law), and others where they are legally allowed to share your personal information with us. For example, if you register to be contacted by prospective employers on another website, the website may provide your personal information to us.

 

• Individuals Who Refer You. Other individuals may give us your personal information. For example, if a friend thinks you may be interested in a job with us, he or she may give us your contact details and resume.

 

• Third-Party employee services. We may also collect information about you from third-party employee services we make available to you as part of your employment with us (e.g., collaboration tools and benefit providers).

 

• Affiliates.  We may also collect information about you from our affiliates or subsidiaries in the ordinary course of business.

 

Combining Personal Information from Different Sources. We may combine the personal information we receive from various sources with personal information we collect from you and use it as described in this Policy.

HOW WE USE YOUR PERSONAL INFORMATION

In general, and subject to applicable law, we may use your personal information for business purposes, including to:

• Recruitment, interviewing, onboarding, training, development, promotion, career, and succession planning.
• Background checks including, where relevant and appropriate, credit checks, right to work verification, identity fraud checks, relevant employment history, relevant regulatory status and professional qualifications
• Providing and administering remuneration, salary, benefits, and incentive schemes and providing relevant information to payroll.
• Allocating and managing duties and responsibilities and the business activities to which they relate.
• Identifying and communicating effectively with other employees and management.
• Managing and operating conduct, performance, capability, absence, and grievance related reviews, allegations, complaints, investigations, and processes and other informal and formal human resources processes and making related management decisions.
• Conducting 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).
• Processing 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.
• For planning, managing and carrying out restructuring or redundancies or other change programs including appropriate consultation, selection, alternative employment searches and related management decisions.
• Operating email, information technology, Internet, intranet, social media, human resources related and other company policies and procedures.
• Complying with applicable laws and regulation (for example maternity or parental leave legislation, working time and health and safety legislation, taxation rules, and other employment laws and regulation to which we are subject in the conduct of our business).
• Monitoring programs to ensure equality of opportunity and diversity with regard to personal characteristics protected under local anti-discrimination laws.
• Planning, due diligence and implementation in relation to a commercial transactions or service transfers (for example mergers and acquisitions or a transfer of your employment under automatic transfer rules).
• For business operational and reporting documentation such as the preparation of annual reports or tenders for work or client team records.
• In order to maintain the relationship with our customers and suppliers including the disclosure of relevant vetting information in line with the appropriate requirements of regulated third parties we do business with.
• Where relevant for publishing appropriate internal or external communications or publicity material including via social media in appropriate circumstances, provided that privacy rights are preserved.
• To support human resources administration and management and maintaining and processing general records necessary to manage the employment or worker relationship and operate the contract of employment or engagement.
• To centralize human resources administration and management processing operations in an efficient manner for the benefit of our employees and to change access permissions.
• To provide support and maintenance of company-issued equipment.
• To enforce our legal rights and obligations, and for any purposes in connection with any legal claims made by, against or otherwise involving you.
• To comply with lawful requests by public authorities (including without limitation to meet national security or law enforcement requirements), discovery requests, or where otherwise required or permitted by applicable laws, court orders, government regulations, or regulatory authorities (including without limitation data protection, tax and employment), whether within or outside your country.
• Other purposes permitted by applicable privacy and data protection legislation.

Other Uses. We may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular individual to help meet our diversity, equity and inclusion goals. Once such information has been aggregated and de-identified it is no longer considered personal information under applicable data protection law.

WITH WHOM WE SHARE YOUR PERSONAL INFORMATION & WHY

Subject to applicable law, we may share personal information in the following circumstances (where applicable):

• Internally. Your personal information may be disclosed to personnel involved in the recruiting and hiring processes, human resources team members, or third-party administrators for recruitment or other legitimate business purposes.
• Service Providers. We may share your personal information with service providers in connection with the provision of services including, but not limited to, the following: recruitment, talent acquisition and administration, technology services, background checks, benefits administrators, payroll provider. We have contracts with our service providers that address the safeguarding and proper use of your personal information. We do not allow our third-party service providers to use your Personal information for their own purposes and only permit them to process your Personal information for specified purposes and in accordance with our instructions.
• Affiliates. We may share your personal information with affiliates for purposes of recruiting or evaluating job applicants and/or candidates, resource planning, and talent and recruitment as well as other legitimate business purposes such as human resources administration and general business management and operations.
• Recruitment Agencies. We may share your personal information with recruitment agencies with whom you provided your personal information or make your personal information publicly accessible to recruitment agencies.
• Your Employer or Organization or Reference Checks. When you apply for a position at our, we may be required to share personal information when we contact your previous or current employer to verify your employment history or your references.
• Public or Government Authorities. We may share your personal information to comply with our legal obligations, regulations, or contracts, or to respond to a court order, administrative, or judicial process, such as a subpoena, government audit, or search warrant where we are legally compelled to do so. We also may share your information when there are threats to the physical safety of any person, violations of our policies or other agreements, or to protect the legal rights of third parties, including our employees, users, or the public.
• Corporate Transactions. Your personal information may be disclosed or transferred to relevant third parties in the event of, or as part of the due diligence for, any proposed or actual reorganization, sale, merger, consolidation, joint venture, assignment, transfer, or other disposition of all or part of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding). If a corporate transaction occurs, we will provide notification of any changes to the control of your information, as well as choices you may have.
• Consent. We may share your personal information in other ways if you have asked us to do so or have given consent.

HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION

We keep your personal information for no longer than necessary to fulfill the purposes for which it is processed. The length of time for which we retain personal information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws as set out in our records retention policy. Generally, this means we retain your personal information to comply with any retention or statutory limitations. In some circumstances we may de-identify or anonymize your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal data in accordance with our retention policy.

Where there are technical limitations that prevent deletion, de-identification or anonymization, we safeguard personal information and limit active use of it.

CALIFORNIA RESIDENTS

Under the California Privacy Rights Act (“CPRA”), California residents have certain rights regarding the personal information that businesses collect about them. This includes the rights to notice, request access to your personal information, [correction of your personal information], deletion of your personal information, [opt-out of sharing (as defined below) personal information], [limit the use of sensitive personal information (as defined below)], as well as the right to direct a business to stop selling (as defined below) your personal information.

Right to Notice. You have the right to be properly notified of the following:

• Personal Information We Collect: Please review the section (above) of this Policy titled “WHAT PERSONAL INFORMATION WE COLLECT & FROM WHOM DO WE COLLECT IT” for more information about the personal information we collected about you.
• Why We Collect Personal Information: Please review the section (above) of this Policy titled “HOW WE USE YOUR PERSONAL INFORMATION” for more information on why we collect personal information about you.
• How We Collect Personal Information: Please review the section (above) of this Policy titled “WHAT PERSONAL INFORMATION WE COLLECT & FROM WHOM DO WE COLLECT IT” for more information on how we collect personal information about you.
• With Whom We Share Your Personal Information: Please review the section (above) of this Policy titled “WITH WHOM WE SHARE YOUR PERSONAL INFORMATION & WHY” for more information on how we share personal information.
• How Long We Retain Personal Information: Please review the section (above) of this Policy titled “HOW LONG WE RETAIN YOUR PERSONAL INFORMATION” for more information on how long we retain your personal information.
• Whether We Collect, Use, Share or Sell Sensitive Personal Information: Please review the section (below) of this Policy titled “WHETHER WE COLLECT, USE, SHARE OR SELL SENSITIVE PERSONAL INFORMATION” for more information on what sensitive personal information we collect, how we use it and whether we share or sell such personal information.

Right to Access Your Information: You have the right to request the following:

• The specific pieces of personal information we have collected about you
• The categories of personal information that we have collected about you
• The categories of sources from which we collected the personal information
• The purpose for collecting or selling or sharing the personal information
• The categories of personal information that we have disclosed about you, the purpose for disclosing such personal information and the categories of third parties with whom we disclosed such personal information
• The categories of personal information that we have sold or shared about you, as well as the categories of third parties to whom we sold or shared such personal information.

If you would like to exercise your right to request access, please submit your request by emailing us at usa-hris-support@us.lactalis.com.  

Right to Correct. You have the right to request that we correct any inaccurate personal information we have collected about you. If you would like to exercise your right to correct, please submit your request by emailing us at usa-hris-support@us.lactalis.com.

Right to Deletion: You have the right to request that we delete any personal information about you that we have collected from you. Please note that there are exceptions where we do not have to fulfill a request to delete information, such as when the deletion of information would create problems with the completion of a transaction or compliance with a legal obligation. If you would like to exercise your right to request deletion, please submit your request by emailing us at usa-hris-support@us.lactalis.com.

Right to Opt-Out of Sharing: The term “share” under the CPRA means sharing, renting, releasing, disclosing, making available, transferring or otherwise communicating orally, in writing, or by electronic or other means an individual’s personal information for cross-context behavioral (targeting advertising to an individual based on personal information obtained from an individual’s activities across third party websites, applications or services) advertising whether or not for monetary or other valuable consideration.  We do not share your personal information for these purposes.

 

Right to Opt-Out of Sale: The term “sale” under the CPRA means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing or by electronic or other means, an individual’s personal information for monetary or other valuable consideration.   We do not sell the personal information we collect from you and only share such information with third parties under contracts that restrict such third party’s use of your data for any purpose other than to provide you the services we contract to receive.

 

Right to Limit the Use of Sensitive Personal Information:  This right is only afforded to individuals if a business uses an individual’s sensitive personal information for purposes not otherwise disclosed to you and as necessary for to perform services or provide products to you.  We do not use sensitive personal information for purposes other than as disclosed and necessary for employment purposes. 

 

The categories listed below are defined as “sensitive personal information” under the CPRA. For each we have described if we collect this information, how we use it and whether such information is “sold” or “shared” 

1. Government identifiers (e.g., Social Security Numbers and driver’s license numbers). This category of sensitive personal information is collected in order to conduct background searches, verify your eligibility to work in the United States and ensure we withhold the correct taxes from your pay.  We do not sell or share this category sensitive personal information.
2. Account log-in information (e.g., financial account or credit card numbers in combination with any required access codes or passwords).  We do not collect, sell or share this category of sensitive personal information.
3. Precise geolocation information.  We do not collect, sell or share this category of sensitive personal information.
4. Racial or ethnic origin, religious or philosophical beliefs, or union membership.  This category of sensitive personal information is collected to help meet our diversity, equity and inclusion goals.  We do not sell or share this category of sensitive personal information. 
5. Content of postal mail, email, and text messages, unless the business is the intended recipient of the subject communications.  This category of sensitive personal information may be collected if you use company email to conduct personal business.  We do not sell or share this category of sensitive personal information. 
6. Genetic data.   We do not collect, sell or share this category of sensitive personal information.
7. Biometric information that uniquely identifies an individual. We do not collect, sell or share this category of sensitive personal information.]
8. Personal information concerning an individual’s health.  We collect this category of personal information to enroll you into health benefits or to investigate and resolve workers compensation claims.  We do not sell or share this category of sensitive personal information. 
9. Personal information concerning an individual’s sex life or sexual orientation. This category of sensitive personal information is collected to help meet our diversity, equity and inclusion goals.  We do not sell or share this category of sensitive personal information. 

 

Right to Not Be Retaliated Against for Exercising Your Rights: We will not retaliate against you for exercising any of the rights afforded to you.

VERIFIABLE CONSUMER REQUESTS: Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access to your personal information twice within a 12-month period. The verifiable consumer request must: 1) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of that person; and 2) Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it. We cannot respond to your request to exercise your access and/or deletion rights if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

RESPONSE TIMING AND FORMAT: We attempt to respond to a verifiable consumer request within 45 days after we receive it. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing within 45 days after we receive your initial request. The response we provide will also provide the reasons we cannot comply with a request, if applicable. For access requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

COMPLAINTS: We commit to resolve complaints about your privacy and our collection or use of your personal information. California residents with inquiries or complaints regarding this Policy should contact us at usa-hris-support@us.lactalis.com.

CALIFORNIA’S SHINE THE LIGHT LAW. California residents with an established business relationship with us can request information once a year about sharing their personal information with third parties for the third parties’ direct marketing purposes. If you would like to request more information under the California Shine the Light law, and if you are a California resident, you can email us at usa-hris-support@us.lactalis.com.

EUROPEAN & UNITED KINGDOM DATA SUBJECTS

 

References to “personal information” in this Policy are equivalent to “personal data” governed by European and United Kingdom data protection legislation. For purposes of European and United Kingdom data protection legislation, unless we collect your personal information from our shared services company, we are the controller of your personal information covered by this Policy.

Lawful Basis for Processing Your Personal Information. If applicable law requires a lawful basis for processing, our lawful basis for collecting and using the personal information described in this Policy will depend on the type of personal information concerned and the specific context in which we collect or use it. Depending on the jurisdiction in which you live, there may be other applicable lawful bases for processing your personal information that are not listed here.

We will only use your personal information as permitted by law. We will typically use your personal information in any of the following circumstances:

1. Where we have your consent to do so, including asking you to provide sensitive information in order to enroll you into health benefits.
2. Where we need to perform our employment obligations or contract we have entered into with you (e.g., ensuring you are paid and proper taxes are withheld in accordance with law).
3. Where we need to comply with a legal obligation, such as verifying you have the right to work in the United States through I-9 verification, handling any legal disputes involving you, and to prevent fraud.
4. Where the processing is necessary to perform a task in the public interest, such as the completion of equality and diversity monitoring forms in order to redress diversity imbalance in the workplace.
5. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, such as to ascertain your suitability for employment with us, to provide you compensation and benefits, to verify relevant qualifications for employment, to conduct investigations in relation to a grievance or disciplinary issues involving you, to conduct performance and appraisal reviews, monitoring our information technology systems in order to ensure compliance with our policies and procedures, to ensure the integrity of our systems, to ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution, collecting CCTV footage for the protection of health and safety (including the identification of individuals on premises in the event of a fire or other serious incident) and the prevention and detection of criminal acts.

 

“Special categories” of personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

 

1. In limited circumstances, with your explicit written consent.
2. Where we need to carry out our legal obligations and in line with our data protection policy and related policies (such as managing sickness absence, complying with health and safety obligations and making reasonable adjustments to your workplace).
3. Where it is needed in the public interest, such as for equal opportunities monitoring (where such information is provided by you).
4. Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards. We may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

If you have questions about or need further information concerning the lawful bases on which we collect, use, store, or otherwise process your personal information, please contact us using the contact details provided below in this Policy.

YOUR RIGHTS: European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

• Right of access. The right to obtain access to your personal data.
• Right to rectification. The right to obtain rectification of your personal data without undue delay where that personal data is inaccurate or incomplete. 
• Right to erasure. The right to obtain the erasure of your personal data without undue delay in certain circumstances, such as where the personal data is no longer necessary in relation to the purposes for which it was collected or processed.
• Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal data in certain circumstances, such as where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data.
• Right to portability. The right to portability allows you to move, copy or transfer personal data easily from one organization to another.
• Right to object. You have a right to object to processing based on legitimate interests and direct marketing.

How to Submit a Request: You can submit these requests by email at usa-hris-support@us.lactalis.com.  We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.

Complaints: If you have a complaint about how we handle your personal information or respond to your request, you may be able to complain to your data protection authority. We ask that you kindly contact us first at usa-hris-support@us.lactalis.com, so that we have an opportunity to resolve your complaint.

TRANSFERS TO THE UNITED STATES

Our offices and operations are based in the United States and that’s where our data processing activities primarily occur.

You acknowledge and agree that any personal information we collect from you or about you will be transferred to, processed, and stored in the United States. The United States does not have an adequacy decision from the European Commission, which means that the Commission has determined that the laws of the United States do not provide legal protection that is equivalent to EU data protection laws. This means that in certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities of the United States may be entitled to access your personal data. Nevertheless, we have implemented appropriate safeguards to protect the personal information we collect.

In addition, and for the purposes described in this Policy, we may transfer your Personal Information from the EEA, the United Kingdom and Switzerland (“European Countries”) to a US-based affiliate or third party. In such cases, and in order to ensure appropriate safeguards for such transfers are in place, we have entered into appropriate standard contractual clauses approved by the relevant regulatory authority with such US-based affiliates and third parties.

LINKED SITES

For your convenience, some hyperlinks may be posted on our websites that link to other websites not under our control. We are not responsible for, and this Policy does not apply to, the privacy practices of those sites or of any companies or organizations that we do not own or control. We encourage you to seek out and read the privacy policy of each website that you visit. In addition, should you happen to initiate a transaction on a website that one of our websites links to, even if you reached that site through our website, the information that you submit to complete that transaction becomes subject to the privacy practices of the operator of that linked site. You should read that site’s terms of use and privacy policies to understand how personal information that is collected about you is used and protected.

COOKIES AND TRACKING TECHNOLOGIES

Cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings.  Browsers offer different functionalities and options, so a user may need to set them separately.  Users should review their browser’s help menu for instructions or visit www.allaboutcookies.org for more information.  Please note that if all cookies are disabled, some features of our websites may not function properly.

DO NOT TRACK SIGNALS

Browser settings may allow users to automatically transmit a “Do Not Track” signal to online services visited.  Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context.  Like many websites and online services, our services are not designed to respond to “Do Not Track” signals received from browsers.

HOW WE SECURE YOUR PERSONAL INFORMATION

We have implemented appropriate technical, physical and organizational measures to protect your personal information from misuse or accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, acquisition, or access as well as all other forms of unlawful processing. To achieve this, we have developed and implemented an Information Security Management System and other sub-policies and guidelines relating to the protection of your personal information. For example, our staff is permitted to access job applicant and/or candidate personal information only to the extent necessary to fulfill the applicable business purpose(s) and to perform their job, subject to confidentiality obligations.

UPDATES TO THIS POLICY

We may modify this Policy from time to time which will be indicated by changing the date at the top of this page. If we make any material changes to this Policy, we will notify you as required by law.

HOW TO CONTACT US

If you have any questions about this Policy or our privacy practices, please contact us at usa-hris-support@us.lactalis.com.