Privacy Notice – California Candidates

1. What is the Purpose of this Privacy Notice?

1.1 Saputo Cheese USA Inc. (“the Company,” “Saputo,” “our” or “we”) are committed to protecting and respecting your privacy. This Privacy Notice describes how we collect, use and disclose personal information about you in connection with the recruitment process, including through our applicant tracking system or otherwise via e-mail or the Saputo communications platform (collectively the “Candidate Portal”).  It applies to all current and former candidates.

1.2 This Privacy Notice does not form part of any contract of employment or other contract to provide services. We may update this Privacy Notice at any time.

1.3 This Privacy Notice applies in connection with your application for work with us (whether as an employee, worker or contractor). Should you be successful in your application, your personal information will then be held in accordance with our Privacy Notice for California Employees, Contractors and Workers. The Privacy Notice is available on our website linked here.

1.4 It is important that you read this Privacy Notice, together with any other Privacy Notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.


2. Your Duty to Inform Us of Changes

2.1 It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.


3. The Kind of Information We Process About You

3.1 In connection with your application for work with us, we will collect, store, transfer, and use the following categories of personal information about you. Some of this information is collected upon your initial application; other information is only collected once an offer has been made to you. We have distinguished where information is only collected upon an offer being made:

• The information you have provided to us in your resume and cover letter including name, contact information, title, address, telephone number, personal email address, gender, work experience, educational qualifications, etc.
• Any of the above information provided on our application form (which is collected after offer) if not already provided on your resume
• Any information you provide to us during an interview
• Results of tests, (e.g. from psychometric testing)
• Information about your health, including any medical condition, disability, injury, health and sickness records
• Where permitted by local law, you have the option of providing certain sensitive personal information with your consent for the purposes of equal opportunities monitoring. This may include information about your race or ethnicity, gender, age, veteran status or disability status, and union membership.

3.2 We also collect, store and use information about criminal convictions and offenses (collected before and after offer).

3.3 We may also aggregate and/or anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. 


4. How is your personal information collected?

4.1 We collect personal information about candidates from the following sources:

• You, the candidate
• Recruitment partners to Saputo, from which we may collect contact details, employment history and academic results
• [Collected after offer] Background check providers, from which we collect the following categories of data: confirmation of employment history (start and end dates) and, for some roles, adverse media checks and criminal history checks, and drug screening
• Your named references (may be collected prior to offer in certain roles or after offer)
• Data from publicly accessible sources such as Facebook, LinkedIn or recruitment websites

5. How We Will Use Information About You

5.1 We have set out below a description of the ways we use your personal information and the legal bases we rely on to do so:

Purpose/Activity	Lawful basis for processing
Assess your skills, qualifications, and suitability for the role	Necessary for our legitimate interests (to decide whether it would be beneficial to our business to appoint you to a certain role)
To decide whether to shortlist you for an interview	Necessary for our legitimate interests (e.g. to decide whether it would be beneficial to our business to appoint you to the role)
To assess your right to work	Necessary to comply with a legal obligation
To decide whether to offer you a certain role	Necessary for our legitimate interests (e.g. to decide whether it would be beneficial to our business to appoint you to a certain role and whether to enter into a contract with you)
Carry out background and reference checks, where applicable (collected after offer)	Necessary for our legitimate interests (to decide whether you would be suitable for the role)
Communicate with you about the recruitment process	Necessary for our legitimate interests (to contact you and keep you informed as to the progress of your application)
Keep records related to our hiring processes	Necessary for our legitimate interests (record keeping)
Carry out equal opportunities monitoring and reporting	Necessary for our legitimate interests (to carry out meaningful equal opportunities monitoring and reporting)
To comply with legal or regulatory obligations	Necessary to comply with a legal obligation
To deal with any complaint or claim	Necessary for our legitimate interests (to investigate and deal with or defend any complaint or claim)
We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview or for you to safely access a site	Necessary to comply with employment and other laws Necessary for our legitimate interests (to provide appropriate adjustments)
We will use information about your race or ethnicity, religious beliefs, sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting	Necessary to comply with employment and other laws Necessary for reasons of public interest (equal opportunities monitoring and reporting) Necessary for our legitimate interests (to ensure meaningful equal opportunity monitoring and reporting, to show we have not acted in a discriminatory way)

5.2 We will only use your personal information for the purposes specified above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose or as otherwise permitted by law. 

5.3 Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


6. If You Do Not Provide Personal Information

6.1 If you do not provide certain information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history documents), we may not be able to process your application successfully.

7. Information About Criminal Convictions

7.1 During the application process, we may process information about criminal convictions. 

7.2 In most cases, we will collect information about your criminal convictions history on application for a role. Once an offer has been made, we will carry out a criminal records check. We are entitled to collect this information in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role.

7.3 If there is a concern with the information you have disclosed and/or the results of the criminal records check, we will make an assessment based on the nature of the concern and the role and may ask you for more information. If we deem you to be unsuitable for the role, we may not be able to take your application any further and/or may withdraw an offer of employment, if already made.
 
7.4 We have in place a data protection policy and safeguards which we are required by law to maintain when processing such data.


8. Data Sharing

8.1 We may share your personal information with third-party service providers and other entities in our group of companies. We require third parties to respect the security of your personal information and to treat it in accordance with the law.

8.2 We share your personal information with companies who perform services on our behalf. These companies are prohibited from retaining, using, or sharing your personal information for any purpose other than providing their services to us. These categories of recipients include portal providers, IT service providers, and background check providers.

8.3 We will only share your personal information with the following third parties where required by law, where it is necessary for the purposes of processing your application or where we have another legitimate interest in doing so.  The categories of third parties with whom we share information are as follows: 

• Third party service providers which provide our IT software and systems, including HR management software;
• Providers of background checking services (including criminal records checks, after an offer is made);
• External advisors, e.g. outside counsel and insurers.

8.4 All our third-party service providers and other entities in the group are required to take reasonable security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal information for their own purposes. We only permit them to process your personal information for specified purposes and in accordance with our instructions.


9. Data Security

9.1 We have put in place reasonable security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. 

9.2 We have put in place procedures to deal with any suspected data security breach and will notify you and the applicable regulator of a suspected breach where we are legally required to do so.


10. Data Privacy Manager

10.1 We have appointed a Data Privacy Compliance Manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact us as follows:

Full name of legal entity:	Saputo Inc.  [Saputo Cheese USA, Inc.]
Contact:	Lydia Pham, Vice President, Legal Affairs –  M&A, Securities and Corporate
Email address:	saputo@saputo.com
Postal address:	Suite 2900 1000 de la Gauchetière Street West, Montréal QC H3B 4W5 Canada

 
11. Changes to this Privacy Notice 

11.1 We will post any future changes to this policy on this page. Please check back frequently to see any updates or changes to this policy.

11.2 This document was last updated on July 14, 2020.

Please feel free to contact us with any questions or comments regarding this Privacy Notice or our personal information practices. You can contact us by email at saputo@saputo.com or by postal mail at:

Suite 2900
1000 de la Gauchetière Street West,
Montréal QC H3B 4W5
Canada