California Employee Privacy Policy

Effective Date: December 31, 2022

BLST Operating Company, LLC, its subsidiary and affiliated companies (collectively, “Bluestem,” “we,” “our,” or “us”), respect the privacy of our employee’s personal information.

Pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”), we are required to provide California employees with a privacy policy that contains a comprehensive description of our online and offline practices regarding our collection, use, sale, sharing, and retention of their personal information as well as a description of the rights they have regarding their personal information. This Privacy Policy provides the information the CCPA requires as well as other useful information regarding our collection and use of personal information.

Please review this Privacy Policy carefully. From time to time, we may change this Privacy Policy. If we do, we will post an amended version on this webpage and on UKG located on Bluestem Connect. You also may receive a copy by contacting us as described in the “How to Contact Us” section below.

This Privacy Policy covers the following topics:

Scope of Privacy Policy

Notice at Collection of Personal Information

Disclosure of Personal Information

Retention of Personal Information

Your Rights

How to Submit a Request to Know, Delete, and/or Correct

Our Process for Verifying a Request to Know, Delete, and/or Correct

Other Relevant Policies, Including Monitoring

Accessibility

How to Contact Us

1. Scope of Privacy Policy

When This Policy Applies

This Privacy Policy is intended solely for, and is applicable only to, current and former California employees. Where relevant, it also applies to job applicants, interns, agency workers, contractors, consultants, directors, and other individuals whose information we collect in connection with providing employment. For ease of reference, this Privacy Policy generally refers to employee data, but this does not indicate in any way that an individual is our employee.

When This Policy Does Not Apply

This Privacy Policy does not apply to individuals who are not California residents.

This Privacy Policy also does not apply to our collection and use of your personal information in a consumer or business-to-business capacity. For more information on our collection and use of your personal information in that capacity, including how we process opt-out preference signals, please see our online privacy policies available at our individual brand websites.

2. Notice at Collection of Personal Information

Personal Information We Collect

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified, or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this Privacy Policy, we will refer to this information as “Personal Information.”

We currently collect and, in the 12 months prior to the Effective Date of this Privacy Policy, have collected the following categories of Personal Information from employees:

Identifiers (name, alias, email address, postal address, Social Security number, driver’s license number, other types of state identification card numbers such as California ID Cards, passport number, Internet Protocol address)

Unique personal identifiers (cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; telephone numbers or other forms of persistent or probabilistic identifiers that can be used to identify a particular employee or device)

Signature

Telephone numbers

Bank account number

Internet or other electronic network activity information (browsing history)

Geolocation data (regional; city/state; precise (1,850 feet or less))

Medical/health information

Insurance policy number or subscriber identification number

Any unique identifier used by health insurer to identify employee

Education information

Professional or employment-related information (including employment history)

Biometric information (imagery of face; voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted; and sleep, health, or exercise data that contain identifying information)

Characteristics of protected classifications under California or federal law (race; sex/gender (including pregnancy, childbirth, breastfeeding and/or related medical conditions); age (40 and older); national or ethnic origin; disability (mental and physical, including HIV/AIDS, cancer, and genetic characteristics); citizenship or immigration status; marital status; military or veteran status; status as a victim of domestic violence, assault, or stalking; and requests for family care leave, for leave for an employee’s own serious health condition, or for pregnancy disability leave)

Audio, electronic, visual, or similar information that is linked or reasonably linkable to an employee

Sources of Personal Information

We collect Personal Information directly from California residents and from recruiters; staffing companies; internet service providers; operating systems, platforms, or software; claims handlers; benefits providers; references; former employers; educational institutions; online providers (such as through LinkedIn and similar providers); government entities; other employees; business partners or coworkers; payroll providers; medical providers; background checks; company bankers; authentication and single sign-on providers; advertising networks; and social networks. We do not collect all categories of Personal Information from each source.

Purposes for Collection

We currently collect and have collected the above categories of Personal Information for all purposes of providing employment, including to:

Perform background checks;

Perform company audits;

Administer and maintain benefits, including group health insurance, retirement accounts, employee compensation, and employee leave;

Process payroll;

Consider you for potential employment;

Request you complete applications and forms associated with your employment or prospective employment;

Verify your ability to work in this country;

Complete new hire reporting;

Administer our wellness program;

Manage workers’ compensation claims;

Detect lost/stolen equipment, fraud, or other types of wrongdoing;

Investigate and handle disciplinary actions or termination;

Comply with federal and state law;

Enforce our legal rights;

Engage in other legitimate business purposes reasonably required for our day-to-day operations such as accounting, financial reporting, and business planning;

Enable recruiting services;

Identify you as a veteran;

Process security clearances;

Perform diversity and inclusion initiatives, including data analysis, development, and deployment;

Request you acknowledge your agreement to certain company policies;

Contact individuals for emergency purposes;

Track time and attendance at work;

Manage your job-related performance;

Arrange business travel;

Establish training and/or development requirements;

Grant and monitor your access to secure company facilities and files;

Engage in corporate transactions requiring review of employee records and information, such as for evaluating potential mergers and acquisitions;

Review web traffic and events, monitor for virus attacks and web content, and determine bandwidth consumption;

Maintain commercial insurance policies and coverages, including for workers’ compensation and other liability insurance;

Maintain commercial licenses for enterprise applications and platforms; and

Prevent the spread of illness and administer programs during a pandemic (e.g., COVID-19).

We also use your Personal Information for the purposes described in our Employee Handbook and Acceptable Use of Technical Assets Policy.

3. Disclosure of Personal Information

The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Effective Date of this Privacy Policy and, for each category, categories of recipients to whom we disclosed Personal Information.

Categories of Personal Information	Categories of Recipients
Personal identifiers (name; alias; email address; postal address; Social Security number; driver’s license number; other types of state identification card numbers; passport number; Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; telephone numbers or other forms of persistent or probabilistic identifiers that can be used to identify a particular employee or device; signature; bank account number; internet or other electronic network activity information (browsing history); and geolocation data)	Background check service providers; benefits providers; payroll/tax providers; expense management service providers; auditors; accountants; company bankers; company insurers; consultants and other professional advisors; compensation management software providers; human resource information systems; operating systems and platforms; government or law enforcement entities; applicant and recruiter software; enterprise travel providers; data analytics providers; authentication and single sign-on providers; security providers; mobile device management providers; lawyers; social networks
Biometric information (sleep, health, or exercise data that contain identifying information)	Employee wellbeing technology provider; benefits providers
Medical and insurance information (medical/health information; insurance policy number or subscriber identification number; any unique identifier used by health insurer to identify employee)	Benefits providers; company insurers
Education, employment history, and related information	Human resource information systems; background check service providers; benefits providers; accountants; company insurers; lawyers
Characteristics of protected classifications under California or federal law (race; sex/gender (including pregnancy, childbirth, breastfeeding and/or related medical conditions); age; national or ethnic origin; disability; citizenship or immigration status; marital status; military or veteran status; status as a victim of domestic violence, assault, or stalking; and requests for family care leave, for leave for an employee’s own serious health condition, or for pregnancy disability leave	Human resource information systems; benefits providers; company insurers; background check service providers; lawyers

We disclosed Personal Information to the above categories of recipients for the following business or commercial purposes:

Perform background checks;

Perform company audits;

Administer and maintain benefits, including group health insurance, retirement accounts, employee compensation, and employee leave;

Process payroll;

Consider you for potential employment;

Verify your ability to work in this country;

Complete new hire reporting;

Administer our wellness program;

Manage workers’ compensation claims;

Detect lost/stolen equipment, fraud, or other types of wrongdoing;

Investigate and handle disciplinary actions or termination;

Maintain commercial insurance policies and coverages, including for workers’ compensation and other liability insurance;

Comply with federal and state law;

Enforce our legal rights; and

Engage in other legitimate business purposes reasonably required for our day-to-day operations such as accounting, financial reporting, and business planning.

We have not sold or shared Personal Information in the twelve (12) months preceding the Effective Date of this Privacy Policy. We do not knowingly collect, sell, or share the Personal Information of individuals under 16 years of age. We do not use Sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations.

4. Retention of Personal Information

We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with services you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us. Please contact us as described in the “How to Contact Us” section below for more information on our employee data retention schedule.

5. Your Rights

If you are a California employee, you have the following rights with respect to your Personal Information:

The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling, or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;

The right to delete Personal Information that we collected from you, subject to certain exceptions;

The right to correct inaccurate Personal Information that we maintain about you;

If we sell or share Personal Information, the right to opt-out of the sale or sharing;

If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and

The right not to receive discriminatory treatment by us for the exercise of privacy rights conferred by the CCPA.

6. How to Submit a Request to Know, Delete, and/or Correct

You may submit a request to know, delete, and/or correct through our interactive webform available here or at http://bluestem.com/ccpa-request-form/ or by calling us at 1-888-959-9737.

If you are submitting a request on behalf of a California employee, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California employee.

In addition to the CCPA rights discussed above, California law provides current and former employees with the right to request certain information relating to their employment, such as the right to access their personnel file and payroll records. Because these requests are governed by laws that contain different requirements than the CCPA, we handle such requests separately from CCPA requests. If you would like to make such a request, please send an email to CAConsumerPrivacy@bluestem.com.

If you would like to update your personal information, such as to notify us of a change of name or address, or if you have questions about your employment, please email CAConsumerPrivacy@bluestem.com.

7. Our Process for Verifying a Request to Know, Delete, and/or Correct

We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California employee on whose behalf you are making such request. Our verification process may differ depending on whether you maintain a password-protected account with us.

If you maintain a password-protected account, we may verify your identity through existing authentication practices available through your account. Prior to disclosing or deleting the Personal Information, we will ask you to re-authenticate yourself with respect to that account.

If you do not maintain a password-protected account, or if you do maintain a password protected account but we suspect fraudulent or malicious activity with your account,] we will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable.

For requests to access categories of Personal Information and for requests to delete or correct Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

For requests to access specific pieces of Personal Information or for requests to delete or correct Personal Information that is sensitive and poses a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

8. Other Relevant Policies, Including Monitoring

When we hire you, we provide you with other policies and procedures that govern your use of our offices, networks, computers, and other devices. We have the right to monitor your use of our offices and electronic resources in accordance with those policies and procedures.

For more information, please read our Employee Handbook, Acceptable Use of Technical Assets Policy, Data Handling Standard and Encryption Standard. You can find copies of these policies at UKG located on Bluestem Connect or by contacting CAConsumerPrivacy@bluestem.com.

9. Accessibility

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below.

10. How to Contact Us

To contact us for questions or concerns about our privacy policies or practices please email CAConsumerPrivacy@bluestem.com.