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Employee and Applicant Privacy Notice

This Privacy Notice was last updated on November 26, 2024

This privacy notice applies to the handling of your personal data as an employee or prospective employee of Schellman Compliance, LLC and its subsidiaries, divisions, affiliates, and related entities ("we," "us," or "Schellman").

We recognize the importance of protecting the privacy of your personal information and want you to be familiar with how we collect, use, retain, and disclose your personal information in connection with your employment.  If you have any questions or comments about the Privacy Notice or our privacy practices, please contact us by email at privacy@schellman.com.

What Personal Data We Process

Schellman collects and processes different types of personal data about employees.  These include the following: 

Data Categories

Examples of what this means

Identification data

Your full name, gender, photograph, date of birth, employee identification number, languages

Contact details

Your home address, telephone, email addresses, emergency contact details

Employment details

Your job title/position, office location, hire dates, employment contracts, performance and disciplinary records, grievance procedures, time records, absence/time off records

Background information

Your academic/professional qualifications, education, résumé, reference letters and interview notes, criminal records data (for vetting purposes, where permissible and in accordance with applicable law)

National identifiers

Your national ID/passport, immigration status and documentation, visas, and social security numbers

Benefits data

Information related to employment benefits we provide to you such as health information (including vaccination status), marital status, name(s) of spouse/dependent(s), birthdates of spouse/dependent(s), vacation, leaves of absence, accommodations information

Financial information

Such as banking details, tax information, payroll information, withholdings, salary, benefits, expenses, company allowances, information regarding assets (including stocks or assets owned)

Workplace, Device, and Usage data

Information required to provide access to Schellman’s IT systems and networks such as IP addresses, log files, login information, software/hardware inventories, geolocation 

Health information

Such as information about short- or long-term disabilities or illnesses that you might share with members of the People & Talent team or your manager, particularly in relation to any leave of absence you may need to take

Other information you choose to share with us

Hobbies, social preferences, etc.

We may also collect certain demographic data that qualifies as sensitive personal data, such as race, ethnicity, and disability to help us understand the diversity of our workforce.  This information, when collected, is generally done so on a voluntary, consensual basis, and employees are not required to provide this information, unless it is necessary for us to collect such information to comply with our legal obligations.  

Most often, the personal data we collect from employees and prospective employees is collected from them directly. In some cases, we may collect personal data about employees or prospective employees from third parties – for example, when we perform background checks that are necessary for the role to be performed by the employee or prospective employee. In most circumstances, we will get your permission before we collect personal data about you from a third party.

While Schellman does not collect biometric data directly, in limited instances, we may utilize a third party who collects and processes biometric information (such as voice fingerprint for intelligent transcription).  In the limited instances where biometric data may be collected, it would be completely voluntary and based upon consent – you would be asked expressly whether you agree to the collection of biometric data prior to any such data being collected.  

If we ask you to provide any other personal data not described above, then the personal data we will ask you to provide, and the reasons why we ask you to provide it, will be made clear to you at the point we collect it.

Why We Use Personal Data

Purpose of processing

Data categories we process

Compensation and Benefits

We use this information to manage payroll, taxes, and benefits as well as to process work-related claims (e.g., worker compensation, insurance claims, expense and travel management) and leaves of absence.

  • Identification data
  • Contact data
  • Employment details
  • Benefits data
  • Health information
  • Financial data

Application for Employment

We use this information to process your application for employment, track your application through the recruitment process, manage communications with you as a candidate, and evaluate you in the recruitment and hiring process

  • Identification data
  • Contact data
  • Employment details
  • Background information
  • National identifiers

Training

We use this information to help us with creating, delivering, and updating training and other development opportunities and enforcing mandatory training completions.

  • Employment details

Performance reviews

We use this information to review how you are performing at work and to help determine your work performance requirements and career development needs.

  • Identification data
  • Contact data
  • Employment data
  • Financial data

Legal requirements

We use this information to comply with laws and regulations (e.g., labor and employment laws, health and safety, tax, anti-discrimination laws) or to exercise or defend our legal rights.

  • Identification data
  • Contact data
  • Employment details
  • Benefits data
  • Financial data
  • Workplace, device, and usage data
  • Demographic data

Contacts

We use this information internally to compile employee directories or send documents or items to home addresses.

  • Identification data
  • Contact data
  • Employment details

Security & Monitoring

We use this information to maintain the security of Schellman’s computing resources, assets, and premises and, provide you with access to them, to manage our general operations and assets, to provide services to you as necessary for your role, and to protect your personal safety.

  • Identification data
  • Contact data
  • Employment details
  • Workplace, device, and usage data

Emergencies

We use this information to help us establish emergency contacts for you and respond to and manage emergencies, crises, and business continuity.

  • Identification data
  • Contact data
  • Benefits data

Investigations and Disciplinary actions

We use this information when necessary to investigate and support decisions on disciplinary actions or terminations, conduct grievance management, or when necessary to detect fraud or other types of wrongdoing.

  • Identification data
  • Contact data
  • Employment details
  • Financial data
  • Workplace, device, and usage data

Day-to-day business operations

We may use this information for other legitimate purposes that are reasonably required for day-to-day operations at Schellman, such as managing our relationship with our employees, accounting, financial reporting, business analytics, employee surveys, operational and strategic business planning, mergers and acquisitions, real estate management, business travel, and expense management.

  • Identification data
  • Contact data
  • Employment details
  • Benefits data
  • Financial data
  • Workplace, device, and usage data
  • Other information you share with us (which may include voice fingerprint/biometric data in limited instances)

When we collect your personal data, we generally do so directly from you or from a third party when you have given us permission. We will only use this data for the reasons we originally collected it and if we need to use the data for another legitimate business reason, we will notify you directly and get your permission where required. If we ask you to provide personal data not described above, the reason for doing so will be made clear to you at the point we collect it.

With Whom Do We Share Your Data?

Third parties are prohibited from using your personally identifiable information beyond providing services to us and are required to maintain the information’s confidentiality and privacy. Schellman does not trade, rent, or sell your personal information to third parties.  Schellman also does not “share” or “sell” your personal information, as those terms are defined in the California Privacy Rights Act. 

Recipients

Why We Share It

Other Schellman Employees and Contractors

  • To establish, manage, or terminate your employment with Schellman

Consultants and Advisors

  • To seek legal advice from external lawyers and advice from other professionals, such as accountants and consultants.

Service Providers

  • To enable third parties to provide services to you on behalf of Schellman such as recruitment providers, financial investment service providers, insurance providers, healthcare providers and other benefits providers, payroll support services.

Clients

  • To enable us to provide services to our clients we may provide them with the names and contact information of Schellman employees.

Partners in Corporate Transactions and their professional advisors

  • In connection with the sale, assignment or other transfer of all or part of our business.

Government Authorities or Law Enforcement

  • If we in good faith believe we are compelled by any applicable law, regulation, legal process or government authority; or
  • Where necessary to exercise, establish or defend legal rights, including to enforce our agreements and policies.

Other Third Parties

  • To protect Schellman’s rights or property;
  • To protect Schellman, our clients, or the public from harm or illegal activities;
  • To respond to an emergency which we believe in good faith requires us to disclose personal data to prevent harm; or
  • With your consent, such as for social events hosted by Employee Advocacy Groups, vendors who help facilitate event/corporate trip planning, or vendors that provide gifts.

Security

The security and confidentiality of your personal information is important to us. We follow reasonable commercial standards for organizational, technical, and administrative measures to protect the personal information submitted to us, both during transmission and once it is received.  

If you believe any personal information you have submitted to us is unsecure or that someone has accessed your account, please notify us immediately at privacy@schellman.com.

How Do You Update Your Personal Data?

It is important that the information contained in our records is both accurate and current. We offer various self-service tools that will allow you to update certain of your personal data in our records via WorkDay. If your personal data changes during the course of your employment, please use these self-help tools to update that data, where available, or open a Schellman Help Center ticket.

How to Request Access to Your Personal Data

WorkDay, Outlook, and several other internal tools allow you to see and/or update personal data that we hold.  If we have personal data that you cannot access via these self-service systems, then you may make a request to the Compliance Team (privacy@schellman.com). We may ask you for information to verify your identity and evaluate your right to access the personal data requested. You can also ask that we delete personal data that you believe is inaccurate or no longer relevant in this same way. Of course, we might need to refuse access to, or deletion of, personal information in certain cases, such as when providing access might infringe someone else’s privacy rights or impact our legal obligations.

Other Rights/Requests Related to Your Personal Data

In addition to being able to update, correct, and access your personal data, you may also have other data protection rights.

For example, if we have collected and processed your personal data with your consent, then you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we carried out prior to your withdrawal, nor will it affect processing of your personal data carried out in reliance on other lawful grounds other than consent.

How Long Do We Retain Your Personal Data?

We will keep your personal data for as long as is needed to carry out the purposes we’ve described above, or as otherwise required by law. Generally, this means we will keep your personal data until the end of your employment with us, plus a reasonable period of time after that where necessary to respond to any employment inquiries, deal with legal, tax, accounting or administrative matters, or to provide you with ongoing retirement plans or other benefits.  For service delivery personnel, we may also retain and otherwise process your personal information for a longer period as required for regulatory and accreditation purposes.

Where we have no continuing legitimate business need to process your personal data, we will either delete or anonymize it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

Questions

If you have any questions or comments about the Privacy Notice or our privacy practices, please contact us by email at privacy@schellman.com.

Updates

We may update this Privacy Notice at any time by publishing an updated version here.  You are bound by any changes to our Privacy Notice after such changes have been posted. Please review the “Last Updated” legend at the top of this page to see when this Privacy Notice was last revised.

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