California Workforce Member Privacy Notice

Effective Date: January 1, 2023

This California Workforce Member Privacy Notice (“Workforce Member Notice”) informs current and former employees, beneficiaries, dependents, and next of kins (“Employee”), and current and former temporary workers, current and former contingent workers, and current and former independent contractors (collectively, “Worker”)(Former Employees and Former Workers, altogether, “Workforce Member”) of Cox Enterprises, Inc. or one of its affiliates, (collectively the “Company” or “we” or “us” or “our”), of our practices regarding the collection, use, sale, sharing, and retention of your personal information (“Information Practices”) to facilitate your employment or post-employment with us as an Employee, including handling of any benefits that may be available to you, or to facilitate your current or post employment, or current or post non-employment worker arrangement with the Company as a Worker (collectively, “Former Workforce Member Personal Information”). 

For purposes of this Workforce Member Notice, Independent Contractor is defined as a natural person who provides any service to a business pursuant to a written contract. Nothing in this Workforce Member Notice shall be interpreted to serve as basis for addressing a Workforce Member’s “employment status” with the Company under California employment laws, including Cal. Labor Code 2750.3.

This Workforce Member Notice should be read in association with all other Company policies that govern your current or previous employment or non-employment worker arrangement with the Company, including, but not limited to our California Applicant Privacy Notice, our California Workforce Member Privacy Notice (Internal) (a copy can be provided upon request), and any additional policies provided to you as part of the off-boarding process. 

If you would like to exercise one of your California Privacy Rights, you may do so by submitting a request by filling out this form including your name, address, email address, and phone number or calling us at 1-855-449-0010 for Cox Automotive, Inc.’s Workforce Members or 1-877-290-myHR (6947) for Cox Communications, Inc. and Cox Enterprises, Inc.’s Workforce Members. Please carefully review Section VII California Privacy Rights before doing so.

During either your employment or non-employment worker arrangement with us, we may have collected, stored, used, and disclosed your Workforce Member Personal Information for business purposes consistent with applicable laws. Where we have transferred your Workforce Member Personal Information to service providers or contractors, it is for the same business purposes or compatible with the same business purposes described below and in Section II and, where appropriate, it is required that such parties maintain its confidentiality and maintain appropriate systems and processes to ensure its security and protection.

Depending on your Workforce Member role as noted below, we may continue to collect, store, use, and disclose the categories of Workforce Member Personal Information about you to facilitate your post-employment or post non-employment worker arrangement with us.

Categories of Workforce Member Personal Information Business Purpose(s) for Collection, Use, and Disclosure
Personal Identifiers such as your name, home address, telephone/cellphone numbers, email address, and/or other similar identifiers. We will continue to use this information to maintain your current or former Employee personnel records or Worker records; communicate with you for current or post employment, or current or post non-employment worker arrangement business purposes or emergencies; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws.

 

Personal Information Described in Subdivision (e) of Section 1798.80 such as name, signature, address, telephone number, national identification number (i.e., Social Security Number, Driver’s License), vehicle information (e.g., car’s year/make/model and license plate), financial information (e.g., bank account details), education, employment, employment history, medical information, and health insurance information.

We will continue to use this information to maintain your current or former Employee personnel records or Worker records; communicate with you for current or post employment, or current or post non-employment worker arrangement business purposes or emergencies; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws.

We will also continue to use any information relating to any disability or health condition to address our legal obligations to you, including to assess your current or post-employment eligibility for and/or pay you any statutory or other benefits to which you may be entitled.

We will also continue to use your financial information to pay you or provide other current or post-employment benefits and process any current or post-employment expense claims.

Characteristics of protected classifications such as age and date of birth, marital status, race, ethnic origin, sex, gender, sexual orientation, gender identity, religion or creed, military or veteran status, medical condition, disability.

Employees only.

We will continue to use this information to maintain your current or former Employee personnel records; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws.

Biometric Information such as facial recognition, fingerprint or hand-geometry data collected by our internal devices, facilities, and any of your devices covered by our Mobile Device Acceptable Use Policy.

For more information on our Information Practices related to your biometric information, current Workforce Members can review our Biometric Information Retention and Destruction Policy posted on our Company Portal.

We will use this to provide access to our systems and facilities, such as laptops, tablets, and cellular phones, including web and mobile applications.

After the off-boarding process or when you are officially a Former Workforce Member of the Company, we will stop using this information and delete from our systems and facilities, such as laptops, tablets, and cellular phones, including web and mobile applications consistent with our Biometric Information Retention and Destruction Policy.

Internet or other electronic network activity information such as all activities on the Company’s information systems, such as internet browsing history, search history, and email communications; and all activity on the Company’s communications systems during your employment or non-employment worker arrangement.

We will continue to use this information to comply with applicable state, federal labor, employment, equal employment opportunity, and related laws.

Geolocation data such as GPS location data from company-issued mobile devices and company-owned vehicles, or otherwise provided by you during your employment or non-employment worker arrangement.

We will continue to use this information to monitor your compliance with our internal policies and procedures, to investigate security breaches and misuse of computer equipment and systems, to protect the safety of employees and third parties, and to protect our property from theft, vandalism, and damage.

We will also continue to use this information to comply with applicable state, federal labor, employment, equal employment opportunity, and related laws.

Sensory information such as security camera recordings (e.g., videos and photos), voice recordings, photographs, phone calls, voice mails, and video calls (e.g., Teams and Zoom meetings and recordings) made during your employment or non-employment worker arrangement.

We will continue to use this information to monitor your compliance with our internal policies and procedures, to investigate security breaches and misuse of computer equipment and systems, to protect the safety of employees and third parties, and to protect our property from theft, vandalism, and damage.

We will also continue to use this information to comply with applicable state, federal labor, employment, equal employment opportunity, and related laws.

We will also continue to use this information for internal and external marketing events, company events, and premise security.

Professional or employment-related information such as position applied for, previous job roles, education, awards, qualifications, certificates, licenses, financial relationships, compensation and salary information, eligibility for and participation in benefit and award programs, and any other information you choose to provide in your resumes and/or applications as well as work anniversary information and skills and experience over the employment period.

We will continue to use this information to maintain your current or former Employee personnel records or Worker records; communicate with you for current or post employment, or current or post non-employment worker arrangement business purposes or emergencies; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws

Non-public education information such as school(s) attended, grades, transcripts, records of attendance, disciplinary records, and other information relating to your secondary and post-secondary education, including any graduate or professional degrees.

Employees only.

We will continue to use this information to maintain your current or former Employee personnel records; communicate with you for current or post-employment business purposes or emergencies; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws

Sensitive Personal Information such as national identification number (i.e., social security number, driver’s license); race or ethnic origin, religious or philosophical beliefs, or union membership; sexual orientation; biometric information; precise geolocation; and information relating to any disability or health condition that is relevant to your role, including the results of any pre- or post- employment physical or screening examination.

We will continue to use this information to maintain your current or former Employee personnel records or Worker records; communicate with you for current or post employment, or current or post non-employment worker arrangement business purposes or emergencies; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws.

We will also continue to use any information relating to any disability or health condition to address our legal obligations to you, including to assess your current or post-employment eligibility for and/or pay you any statutory or other benefits to which you may be entitled.

Other Categories of Former Workforce Member Personal Information

National identification information such as your country of birth or the country where you are a registered national or citizen, and any visa or other right to work.

Benefits information such as national insurance numbers, and information about your pension and other welfare or benefits. This may also include information about any beneficiaries, dependents, emergency contacts and next of kin.

Employees, beneficiaries, and dependents only.

We will continue to use this information to maintain your current or former Employee personnel records; communicate with you for current or post-employment business purposes or emergencies; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws.

We will also continue to use this information to assess your current or post-employment eligibility for and/or pay you any statutory or other benefits to which you may be entitled.

We will also continue to use this information to contact the designated contacts in the case of an emergency.

In addition to the business purposes set forth above, we may collect, use, and disclose the categories of Workforce Member Personal Information identified above:

  • To comply with applicable legal and regulatory requests and obligations (including investigations).
  • To establish or defend legal claims and allegations.
  • For security or the prevention, detection, or investigation of fraud, suspected or actual illegal activity, violations of company policy or rules, or other misconduct.
  • To seek advice from lawyers, auditors, and other professional advisers.
  • To disclose to another party in connection with the sale, assignment, merger, reorganization, or other transfer.

We may also use and disclose the categories of Workforce Member Personal Information identified above for the following business purposes:

  • Helping to ensure security and integrity to the extent the use of your Workforce Member Personal Information is reasonably necessary and proportionate for these purposes;
  • Debugging to identify and repair errors that impair existing intended functionality;
  • Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf;
  • Undertaking internal research for technological development and demonstration; and
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Workforce Member Personal Information (which includes the categories of PI set forth in the chart above) for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal obligations, or as necessary to resolve disputes.

To determine the appropriate retention period for Workforce Member Personal Information, we consider applicable legal requirements, the amount, nature, and sensitivity of the Workforce Member Personal Information, the potential risk of harm from unauthorized use or disclosure of your Workforce Member Personal Information, the purposes we process your Workforce Member Personal Information for, and whether we can achieve those purposes through other means.

As you leave the Company, and depending on your Workforce Member role,  we may retain your Workforce Member Personal Information for as long as required by applicable laws, including but not limited to: Title VII of the Civil Rights Act of 1964; the Age Discrimination in Employment Act of 1967; American Disabilities Act of 1990; Fair Labor Standards Act; Family Medical Leave Act; Immigration Reform and Control Act; Immigration and Nationality Act; Employee Retirement Income Security Act; Federal Insurance Contribution Act; Internal Revenue Code; Occupational Health & Safety Act; and for California Employees, California Government Code Section 12946; or as required by our non-employment worker arrangement(s) and agreement(s).

For example, under the Employee Retirement Income Security Act or ERISA, any Workforce Member Personal Information used to determine benefits that are or will become due for each Employee participating in the plan must be retained as long as they are relevant (i.e., as long as employee benefits are due and payable).

To carry out the purposes described above, we may disclose your  Workforce Member Personal Information to the following recipients: data analytics providers, security providers, background check vendors, human resources and information technology vendors. affiliates, outside legal counsel, and state or federal governmental agencies.

We may have collected  Workforce Member Personal Information from our Talent Community and Applicant Tracking System (the “Applicant Site”) when you were a job applicant, from the Company Employee Portal (the “Employee Site”) (collectively, “CEI Employment Sites”), and from a variety of sources to facilitate your current or former employment, or current or former non-employment worker arrangement with us, to comply with applicable laws, and other permitted business purposes.

  1. Directly From You. For example, we collected your name, home address, telephone/cellphone numbers, email address, and other employment-related information when you applied for a job as an applicant and when you were onboarded as an employee.
  2. Automatically When Using Our Electronic Systems. For example, our internal electronic systems automatically collected your internet and network activity information.
  3. Service Providers and Contractors. For example, background check vendors, recruitment and staffing agencies, credit agencies and bureaus, and benefit providers.
  4. Affiliates.

We will not share or sell your Workforce Member Personal Information to third parties.

If you are a resident of California, you have the right to submit certain requests relating to your Workforce Member Personal Information as described below.

Right to Opt-Out of Share and Sale of Workforce Member Personal Information.

As stated above, we will not share or sell your Workforce Member Personal Information to third parties. For this reason, we do not treat Workforce Member Personal Information collected by us as subject to a “Do Not Share or Sell” request and, therefore, we do not offer a way for you to submit such a request.

Right to Limit Use and Disclosure of Sensitive Personal Information.

We will not use Sensitive Personal Information for the purpose of inferring characteristics about you, or for any other reasons besides the permitted purposes including: to provide our goods and services; to ensure security and integrity; to prevent fraud or illegal activity; for physical safety; for short-term, transient use, including for non-personalized advertising; to perform services on behalf of the business; and to verify or maintain the quality or safety of a service or device owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance such services or devices. For this reason, we do not treat the Sensitive Personal Information we collect as subject to a “Limit the Use of My Sensitive Personal Information” request and, therefore, we do not offer a way for you to submit such a request.

Right to Know, Delete, and Correct Workforce Member Personal Information.

Any Request to Know, Request to Delete, and Request to Correct you submit to us is subject to an identification and residency verification process (“Verifiable Workforce Member Request”). We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the Employee or Worker about whom we collected Workforce Member Personal Information.

If you are unable to provide us with certain information about yourself or, in some cases, we will be unable to verify your identity to fulfill a request to know, delete, or correct. In some cases, we may verify identity by confirming that you are the owner of the email address we have on file. For your specific pieces of information, as required by the California Consumer Privacy Act (“CCPA”), we will apply heightened verification standards, and reserve the right to request further information from you, in addition to the information mentioned above.

We will make commercially reasonable efforts to identify Workforce Member Personal Information that we collect, process, store, disclose, and otherwise use and to respond to your requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.

You may use an authorized agent to submit your request. If you use an authorized agent to submit a request, we may require proof that the agent has been authorized by you to do so, and take other steps permissible under the CCPA, to ensure it is a proper request by an authorized agent.

Right to Know. You have the right to send us a request, no more than twice in a twelve-month period, for any of the following:

  1. The categories of Workforce Member Personal Information we have collected about you, including:
    1. The categories of sources from which the Workforce Member Personal Information was collected
    2. Our business or commercial purposes for collecting Workforce Member Personal Information
    3. The categories of third parties to which we disclose Workforce Member Personal Information
    4. The categories of Workforce Member Personal Information that we disclosed for a business purpose, and for each category identified, the categories of third parties to which we disclosed that particular category of Workforce Member Personal Information
  2. The specific pieces of Workforce Member Personal Information we have collected about you.

Right to Delete. You may request that we delete your Workforce Member Personal Information that we have collected directly from you and are maintaining. Exceptions do apply, including, without limitation, where we need to retain your Workforce Member Personal Information as permitted by applicable law, such as for legal retention requirements, regulatory reasons, to complete a warranty or other contract with you, or other internal uses of the information that are compatible with the context in which you provided it.

For example for former Employees, we may not be able to delete your benefits information, including information about any beneficiaries, dependents, emergency contacts and next of kin because we may need it to facilitate your post-employment benefits such as 401(k) or other retirement plans that may be available to you. We may also not be able to delete your health insurance information if you decide to sign up for Continuation of Health Coverage under the Consolidated Omnibus Budget Reconciliation Act (COBRA).

Note also that we are not required to delete your former Workforce Member Personal Information that we did not collect directly from you.

Right to Correct. If you believe that any of your Workforce Member Personal Information, we maintain about you is inaccurate, you have the right to request that we correct that information.

To exercise the right to know, right to delete, or right to correct, you may submit a request by filling out this form including your name, address, email address, and phone number or calling us at 1-855-449-0010 for Cox Automotive, Inc.’s Workforce Members or 1-877-290-myHR (6947) for Cox Communications, Inc. and Cox Enterprises, Inc.’s Workforce Members. Do not send other information via e-mail. We will contact you for further information if necessary. In order to complete your request, you will be required to respond to any follow up inquires we may make, and we may deny your request if you do not do so.

Right to Non-Discrimination for the Exercise of Your Privacy Rights.

If you choose to exercise any of your privacy rights under the CCPA, we will not discriminate against you.

We reserve the right to amend this Workforce Member Notice at any time in order to address future developments of Company or changes in industry or legal trends. We will post the revised Workforce Member Notice on our website or inform you through various methods.

If you have any questions about this Workforce Member Notice, please contact us at privacy@coxinc.com. Note that CCPA requests under Section VIII California Privacy Rights will not be accepted via email.

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