Personnel Notice and Collection Policy

1.0  PURPOSE

The purpose of this Personnel Notice and Collection Policy (the “Policy”) is to describe how San Jose Water Company (“San Jose Water,” “we,” “us,” and/or “our”) handles Personal Information, defined below, we collect from employees, contractors, consultants, and other individuals (collectively, “personnel”) who currently work or previously have worked for San Jose Water, as well as individuals who have applied to, or been recruited by San Jose Water in accordance with Privacy and Data Security Laws, as defined below. This Policy explains the types of Personal Data we collect, how we may use and share the data, and the choices that are available to you with respect to our handling of your data. This Policy should be read in conjunction with other applicable privacy policies that San Jose Water has adopted to comply with Privacy and Data Security Laws, as well as employee handbooks and related documents. For additional information on applicable policies, handbooks and related documents, please contact the Human Resources department.

2.0  SCOPE

This Policy pertains to all San Jose Water employees, independent contractors, and applicants for employment at San Jose Water.

3.0  DEFINITIONS

3.1  “Personal Information” - Shall have the meaning of such term or like terms set forth in the Privacy and Data Security Laws (defined below), including name, email, physical address, employee identifier, government identification, device identifier, and any other information that can be used to re-identify a person.

3.2  “Privacy and Data Security Laws” - Relevant data protection laws governing privacy, data security, cybersecurity and Personal Information, e.g., the California Consumer Privacy Act of 2018 and other similar laws and regulations in the U.S. where San Jose Water has physical operations, employees or directs business (collectively, the “Privacy and Data Security Laws”).

4.0 POLICY

San Jose Water shall process the Personal Information of personnel who currently work or previously have worked for San Jose Water, as well as individuals who have applied to or been recruited by San Jose Water, in accordance with Privacy and Data Security Laws.

4.1  Information We Collect

We collect different types of information depending on if you are current or former personnel, or have applied for, or are recruited for a job at San Jose Water. We collect information you provide directly to us, as well as information on you that we obtain from third parties. The types of Personal Information we may collect depend on the jurisdiction, and include but are not limited to:

• Contact information, such as your name, email address, mailing address, and phone number;
• Government or national identification information, such as your driver’s license number, passport number, national insurance or social security number, and visas and work authorizations;
• Recruitment information, such as your resume, cover letter, references, and employment application;
• Payroll information, such as your banking and direct deposit forms, salary, tax forms, expense reimbursement records, and vacation and PTO balances;
• Information to support our Commercial Drivers’ Licensing Program, including results of medical screenings and driving infractions;
• Education and certification records; including continuing education credits, grade reports, test results, and transcripts;
• Performance information, such as performance reviews and disciplinary reports;
• Photo for badge and employee directory;
• Names and other personal information for communications, marketing and/or public relations purposes;
• Benefits information, such as your benefits elections, beneficiaries, spousal or partner information, and dependent information;
• Health information of employees or independent contractors, or applicants in accordance with governmental orders or other regulatory, or health and safety practices related to the COVID pandemic response or other public health reasons; and
• Other information that supports our human resources or our business operations.

We may also collect information about your use of company technology and resources, including email, instant messaging, file share and employee collaboration platforms, IT help desk, and employee training tools, as permissible under applicable laws.

Some San Jose Water sites are equipped with surveillance equipment such as cameras and closed-circuit television which may capture your images or information about your movements, and which are used to protect the safety of San Jose Water staff, visitors, and San Jose Water equipment.

4.2  How We Use Your Information

We use your Personal Information to support San Jose Water’s human resources and other business purposes, in our legitimate interests and as permissible under applicable laws, including:

• Recruitment, such as evaluating an application for employment, conducting interviews, conducting background checks (when we have your consent), and deciding terms of an employment offer;
• Personnel management, such as monitoring assignments, evaluating performance, training employees, communicating with you, and responding to your requests, inquiries, and comments;
• Operational purposes, such as distributing payroll and company benefits, updating personnel files, conducting audits, and providing IT support and other troubleshooting;
• Legal and compliance purposes, such as implementing internal policies, responding to suspected fraud or other illegal activity, protecting San Jose Water’s and others’ rights and property, and complying with laws, legal processes, or governmental requests or orders;
• Internal communications purposes.

4.3  How We Share Your Information

We do not share your Personal Information except in the limited circumstances described below:

• With a restricted number of San Jose Water personnel and affiliates to carry out human resources and other business operations to perform certain functions that the employee may not be able to perform themselves (e.g., securing health benefits);
• With external third parties that perform these operations on our behalf (e.g., health insurance and IT companies);
• With legal or regulatory authorities to comply with our obligations, to protect the rights and property San Jose Water, our customers, and the public, and to detect and respond to suspected illegal activity and threats to the safety of any person or of our systems or services;
• In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company, as allowed by law; and
• With your consent and at your direction as permissible under applicable law (including for financial transactions).

4.4 Changes to Our Policy

We may change this Policy from time to time. Each version of this Policy is identified by its effective date.

4.5 Contact Us

If you have questions or concerns regarding this Policy, you may email us HR_DEPT@sjwater.com. More information about how to contact San Jose Water is available on our Contact Us page.