ARAMARK WORKFORCE PRIVACY NOTICE - US
Effective date: January 1, 2020
This notice (Notice) sets out how Aramark collects, uses, stores and shares personal information about our staff, including our current and former employees, temporary staff, consultants, contingent workers and interns (staff or you or your). This Notice also applies to applicants of Aramark. For purposes of this Notice, Aramark refers collectively to the Aramark group company that employs or engages you or any of its affiliate entities (“Aramark” or “we” or “our”). These companies can be reached using the relevant contact details set out in the “Your contact for any queries” Section below. 1 Information we collect about you
For purposes of this Notice, personal information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information excludes deidentified information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular consumer. We will collect and use some or all of the following personal information before, during, and after your employment (or similar engagement):
(a) Identifiers, such as name, date and place of birth, email, social security number, drivers’ license number, current and prior postal addresses, phone numbers;
(b) Professional or employment information, such as department, work location, job title information, absences from work, performance information, criminal history, performance evaluations, job referral information, union membership (if applicable), and dependents’ information;
(c) Internet or electronic network activity information, such as details of your use of and communications sent through Aramark systems and geolocation information;
(d) Commercial information, such as details of travel that you undertake, or expenses you incur, in connection with your employment or engagement;
(e) Protected classifications, such as your race, gender, age, marital status, or military or veteran status, medical information, and disability status;
(f) Education information, such as your prior training;
(g) Financial information, such as your bank account information;
(h) Driving history, drug testing and criminal history;
(i) Other information provided by you, including internal survey responses. 2 How we use personal information
The purposes for which we use your personal information are as follows:
(a) Recruiting and Hiring, such as determining your eligibility for work, checking references, and performing background checks.
(i) For recruiting purposes and to help us determine your ability to perform the job, we process your identifiers, professional or employment information, and education information.
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(b) Conducting checks, such as background checks, credit checks, anti-fraud checks, checks to prevent fraud and money laundering and drug tests, to the extent allowed under applicable employment laws.
(i) For purposes of conducting checks, we process your identifiers, protected classifications, professional or employment information, and driving history and drug history.
(c) General HR administration, such as staff communications, on-boarding and off-boarding, succession planning, managing your career development, assessing your suitability for a particular role, assessing your salary and other compensation, and performance.
(i) For our general HR administration, we process your identifiers, professional or employment related information, education information, protected classifications, and financial information.
(d) Administering salary, expenses, and staff benefits, including administering insurance, payroll, retirement plans, and other employee benefits and tax, and in order to administer corporate expenses and reimbursements (including viewing details of transactions made using corporate credit cards and corporate travel undertaken)
(i) To administer salary, expenses, and benefits, we process your professional or employment information, commercial information, and financial information.
(e) Managing absences and occupational health requirements, including to keep a record of absences and to contact dependents or other family members in the event of an emergency.
(i) To manage absences and occupational health requirements, we process your identifiers, professional or employment information and protected classifications.
(f) Monitoring, such as monitoring for compliance with Aramark policies provided to you and limited monitoring of information technology systems (including communications transmitted through these systems) solely to the extent permitted by applicable law, including to prevent, detect and fight fraud or other illegal or unauthorized activities.
(i) For monitoring and security purposes, we process your identifiers, internet or electronic network activity information, and employment or professional information.
(g) Information Technology (IT) purposes, such as providing IT support for Aramark Information Systems and user authentication.
(i) For IT purposes, we process your identifiers, professional or employment information, and internet or electronic activity information.
(h) Storing staff communications, records and work product, including as required in order to operate the Aramark business. These communications and records may contain personal information both related to work and private matters.
(i) For storing staff communications, records, and work product, we process your identifiers, professional or employment information, and internet electronic activity information.
(i) Complying with our legal obligations, like monitoring equal opportunities, complying with audits, or where necessary, for exercising, establishing, or defending legal claims, including the disclosure of your personal information to third parties in connection with proceedings or investigations anywhere in the world, such as public authorities, law enforcement agencies, regulators and third party litigants. 3
(i) For these purposes, we collect your identifiers, protected classifications, employment and professional information, and internet or electronic network information.
(j) When changing our business structure, such as in the event of a business sale or corporate restructuring, where we may disclose your personal information to any potential acquirer of, or investor in, any part of the Aramark business (and to their legal advisors and consultants) for the purpose of that acquisition or investment.
(i) For this purpose, we process your identifiers, employment or professional information, and protected classifications.
3 How we share personal information
In connection with the purposes listed above in section 2 and consistent with this Notice:
(a) The Aramark group company that employs or engages you shares your personal information with Aramark affiliates where required for Aramark’s internal administrative purposes. Aramark may grant other group entities access to such data where required for the purposes consistent with this Notice.
(b) In limited situations, Aramark may share your personal information with certain third parties for the purpose of managing Aramark’s relationship with its clients and related parties, such as unions.
(c) Subject to local legal requirements, we may use third parties to assist us with human resources and IT related services, such as payroll providers, healthcare providers, insurers, retirement administrators, information systems storage providers, IT managed service providers, accountants and legal advisors, and other third party vendors that need your personal information to provide their services. We require that such external service providers or third parties will ensure adequate protection for your personal information and will comply with local legal requirements and our privacy and data security standards.
(d) In addition, we may share your personal information with other third parties where disclosure is permitted or required by law to comply with legal obligations, protect our rights and property, or protect the safety of our staff or any third party. 4 Storage of personal information
We will retain your personal information for as long as is necessary for the purposes for which it was collected and any other permitted or required purposes (such as to comply with regulatory requirements to retain such information). Our retention periods are based on business needs and relevant laws. Please note that these periods may be extended where reasonably necessary (for example where we are required to do so by law or by a regulator). We will either deidentify or securely destroy personal information that we no longer need. We reserve the right to use deidentified information for any legitimate business purpose without further notice to you or your consent.
5 Your contact for any queries
If you have any queries or concerns regarding personal information, please contact us at: *******@*******.***
VP, Compliance
Aramark
2400 Market Street
Philadelphia, PA 19103
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6 Changes to this Notice
This Notice was last updated on the effective date listed at the top of this Notice. We will notify you of any material changes to this Notice by posting information about the change on the Intranet or by other reasonable means, prior to the change taking effect.