Workforce Notice About Your Personal Information

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1. Overview

This Notice explains your rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CPRA”) (Cal. Civ. Code § 1798.100 et seq.) and helps you understand how Harmony Foods, LLC dba SCN BestCo collects, uses, and retains your Personal Information in compliance with California law. In this Notice, the terms “Company,” ”us,” “we,” and “our” refer to SCN BestCo and its affiliates and subsidiaries.

2. Who This Notice Applies To

The CPRA provides a right to notice at collection for certain California residents including current and former employees, and owners/officers/directors (“Workforce” or “you”); emergency contacts provided by Workforce; and individuals/dependents of Workforce whose Personal Information is provided to administer benefits.

3. What Information We Collect

As further described below, the Company collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“Personal Information”). Personal Information does not include publicly available information from government records, deidentified information, or aggregated data.

As described in greater detail, below, we collect Personal Information in the following ways:

Directly from You. We may collect Personal Information directly from you, such as during the job application or onboarding process, during your employment, and/or when you experience a change in your employment status with the Company.

From Third Parties. We may collect certain Personal Information about you from third parties. For example, this includes from vendors that run background checks and perform drug and alcohol screenings, or vendors that administer the Company’s leave of absence and disability benefits. This also includes information from references. Other employees may provide us with information about you, such as performance or evaluation information from a manager or supervisor. We may combine information that we collect from different sources.

Please note that Personal Information does not include information based on activities performed on company assets. You do not own or have an expectation of privacy or rights under the CPRA regarding:

(a) Company information created, collected, or maintained on any technology assets owned, leased, or operated in whole, or in part, by the Company. The Company’s technology assets consist of all electronic devices, software, and means of electronic communication, including, but not limited to, computers and workstations, laptop computers, computer hardware, as well as computer software applications, associated files, and data that grant access to services like the internet, email, phone, voicemail, and instant messages. All information created, collected, or maintained by the Company’s technology assets is company property and provided to you solely for your use in conducting company business.

(b) Company information SCN BestCo collects when monitoring premises, equipment, devices, computers, network, applications, software, or similar company assets and resources, to protect its worksites, employees, and computer systems.

3.1. Categories of Personal Information

The following discusses the categories of Personal Information we collected in the last twelve (12) months. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different purposes without first providing you notice.

Personal Identifiers. We collect your name, signature, employee number, driver’s license or ID, email address, phone number, mailing address, and emergency contact information from you during our application and onboarding processes and if you update your information with us. Additionally, we collect your social security number, passport number, tax identification number, or other I-9 documentation to show your identity and authorization to work.
Characteristics of Protected Classifications Under California or Federal Law. We may collect your date of birth, age, gender identity, race, racial or ethnic origin, citizenship, veteran status, disability information, marital status, or pregnancy and related information, if you provide this information as part of your application, during onboarding, or while working at SCN BestCo.
Audio, Visual, or Similar Information. We may collect information that may be used to identify you to other employees and/or our security personnel, such as your employee photograph or CCTV security camera recordings.
Biometric Information. During your employment with us, we may collect characteristics about you that can be used to establish your identity, such as your fingerprints.
Professional or Employment-Related Information. We collect information related to your employment history during the application process. Additionally, we collect information from you during your employment with us, such as dates of employment, your work attendance, and records pertaining to your work performance.
Education Information. We collect your education history from you as part of your application or if you update your information with us.
Financial Information. We collect financial information, including when you provide us your bank account information to process payroll.
Health Insurance Information. We collect health insurance information such as your policy number, coverage information, dependent or spouse information, worker’s compensation, requests for disability accommodation, or any similar request.
Medical Information. To the extent permitted and required by applicable laws, we may collect information about your health, medical and treatment history, diagnoses, dates of service, provider name, and your ability to work.

The following forms of data listed above constitutes “sensitive personal information”: Your social security, driver’s license, state identification card, or passport number; your bank account information; your racial or ethnic origin; your citizenship status; your immigration status; your biometric information; and your health information, if provided to us.

4. How We Use the Information We Collect

We use the Personal Information we collect for the following purposes:

Onboarding. We use Personal Information to complete new hire paperwork, enroll you in our HR system, and set up your personnel file.
Benefits. We use the Personal Information we collect to create benefits packages and, if eligible, provide you employee benefits through third-party benefits administrators.
Payroll. We use Personal Information to manage and pay you for services provided.
Leave and Accommodation Requests. We use the Personal Information we collect to evaluate and process time off, sick leave, leaves of absence, or accommodation requests, if you make such requests.
Training, Performance Reviews, and Goals Monitoring. We use the Personal Information we collect to provide you with relevant training, feedback, and to support your career development.
Business Operations. We use Personal Information to guide our recruiting and hiring process, maintain files, and support our business operations and the operations of our parent(s), subsidiaries, and affiliates.
Security and Crime Prevention. We use Personal Information to secure our facilities and networks, such as by monitoring access to our network; conducting periodic security checks; and limiting access to our facilities.
Legal Compliance and Protection. We use the information we collect to comply with applicable laws, our legal obligations and in our defense of our company, property, and others through legal proceedings.

5. Additional Rights Under California Law

You may have certain rights under California law. This may include a right to access, correct, or delete employee data, subject to applicable exceptions. For example, we may retain your employee data to comply with legal obligations. To exercise your rights, contact us as described at the end of this notice, or use the webform here: https://www.scnbestco.com/privacy-form/ on our website to submit a request.

Under California law, we are required to tell Californians if we “sell” or “share” information as that term is defined by applicable law. Sell is defined under the law as disclosing personal information to a third party for monetary or other valuable consideration. Share is specifically defined under the law as well. Sharing means sharing personal information with a third party for cross-context behavioral advertising.

We do not do “sell” or “share” employee data (including personal information and sensitive personal information) based on our understanding of those terms. If you interact with the Company in other ways you may have different rights. For example, if you use our website, visit our website privacy policy for information collection and rights for website users. If you are also a Company customer or consumer, the privacy policy on our website applies to our interactions with you as a customer or consumer.

Other rights to inspect and access certain payroll and employment records remain available pursuant to the California Labor Code.

6. How We Retain Your Personal Information

To the extent permitted by applicable law, the Company will retain your Personal Information for as long as reasonably necessary to fulfill the purposes for which it was collected, including to meet any legal, accounting, or other reporting requirements or obligations. We use the following criteria to determine retention periods:

how long the information is needed to provide our services and operate our business;
whether there are contractual or legal obligations that exist that require us to retain the information for period of time;
whether any law, statute, or regulation allows for a specific retention period;
whether an individual has agreed to a longer retention period;
whether the data is considered to be sensitive data; and
what the expectation for retention was at the time the data was provided to us.

7. How You Are Protected Against Discrimination & Retaliation

The Company will not unlawfully discriminate or retaliate against you for exercising any of your rights under the CPRA. This commitment applies to all persons involved in our operations and prohibits unlawful discrimination or retaliation by any employee of the Company, including supervisors and coworkers.

8. How Other SCN BestCo Policies & Disclosures Apply

This Notice is in addition to the policies and disclosures found in the Employee Handbook. If you are unsure whether this Notice applies to you, please contact Human Resources.

9. Disclaimer

Nothing in this Notice restricts the Company’s ability to:

Comply with federal, state, or local laws;
Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
Cooperate with law enforcement agencies concerning conduct or activity that the business, service provider, or third party reasonably and in good faith believes may violate federal, state, or local law;
Exercise or defend legal claims;
Detect security incidents and protect against fraudulent or illegal activity and prosecute those responsible for such activity; or
Transfer Personal Information as part of a merger or acquisition, dissolution, bankruptcy, or any other transaction in which a third party assumes control of all or part of the Company.

10. Changes to This Notice

This Notice is reviewed and updated annually to ensure it accurately captures our practices and procedures. The effective date of this version is posted below.

11. Privacy Policy

Our Privacy Policy for employees may be found here:
https://www.scnbestco.com/employee-privacy-policy/

12. Resolving Concerns and How to Contact Us

If you have questions or concerns regarding this Notice or the handling of your Personal Information, please contact us at benefits@scnutr.com.

EFFECTIVE DATE: December 01, 2023