Privacy Notice for Job Applicants, Employees, Contractors, and Their Emergency Contacts

Last Updated: September 1, 2022

This Privacy Notice for Job Applicants, Employees, Contractors, and Their Emergency Contacts (“Privacy Notice”) applies to job applicants, employees, contractors, and their emergency contacts (“employee” or “you”). It does not apply to personal information covered by HIPAA or to publicly available, deidentified, or aggregated personal information.

For purposes of this Privacy Notice, “Great American”, “we”, and “us” means the U.S.-based insurance companies and operations that make up the Great American Insurance Group.**

This Privacy Notice pertains to personal information we may have collected in the last twelve (12) months.

** For business based in Canada, Europe, UK, Singapore, and Mexico, please refer to your compliance or HR department representative for a copy of your local privacy notice.

Personal Information We Collect

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information” or “PI”). We may collect the following categories of your personal information:

Category of Personal Information	Examples
Identifiers (“Identifiers”)	Name, alias, postal address, social security number, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.
Categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)) (“Other PI”)	Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, or any other financial information or health information. Some personal information included in this category may overlap with other categories.
Sensitive (“Sensitive”)	Personal information that reveals an employee’s social security, driver’s license, state identification card, or passport number; an employee’s account login, or corporate credit card number in combination with any required security or access code, password, or credentials allowing access to an account; an employee’s precise geolocation; an employee’s racial or ethnic origin or religious or philosophical beliefs; the contents of an employee’s mail, email and text messages that are sent or received using applications or equipment owned or controlled by us, unless we are the intended recipient of the communication; the processing of biometric information for the purpose of uniquely identifying an individual; personal information collected and analyzed concerning an employee’s health. Some personal information included in this category may overlap with other categories.
Characteristics of protected classifications under California or federal law (“Characteristics”)	Age (40 years and older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy, or childbirth and related medical conditions), sexual orientation, and veteran or military status.
Commercial information (“Commercial”)	Records of personal property, products, or services purchased, obtained, or considered.
Biometric Information (“Biometric”)	Physiological, biological, or behavioral characteristics, such as fingerprints.
Internet or other electronic network activity information (“Internet Activity”)	Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
Geolocation data (“Geolocation”)	Physical location and/or movements.
Sensory data (“Sensory”)	Audio, electronic, visual, or similar information.
Professional or employment-related information (“Professional”)	Current and/or past employment history, professional licenses, or affiliations. Education records for maintaining continuing education requirements.
Non-public education information (as defined in the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)) (“Education”)	Education records, files, documents, and other materials directly related to a student maintained by an educational agency or institution or by a person acting for such an agency or institution, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records
Inferences drawn from other personal information (“Inferences”)	Information used to create a profile about an employee reflecting the employee’s preferences, characteristics, predispositions, behavior, attitudes, abilities, and aptitudes.

Uses and Disclosures of Personal Information

We may use the categories of personal information for the following purposes:

Category of Personal Information	Purposes
Identifiers Other PI Sensitive Characteristics Commercial Internet Activity Geolocation Sensory Professional Education Inferences	To fulfill or meet the purpose for which you provided the information To contact you with regard to your relationship with us, respond to your inquiries, and otherwise communicate with you To contact third parties whose contact information you provide to us in case of an emergency or otherwise as permitted by applicable law To allow you access to our technology assets, accounts, and physical premises To help maintain the safety, security, and integrity of our technology assets, information, or accounts you may have with us, and our physical premises To administer our policies and procedures and to investigate any potential violations of our policies or procedures or contract of employment To report information to government agencies as required by applicable law, and otherwise to comply with applicable laws and government programs in which we participate To respond to law enforcement requests and as required by applicable law, court order, or local, state, or federal government regulations As necessary or appropriate to protect the rights, property, or safety of us, our clients, or others, including in connection with obtaining legal advice or establishing or defending our rights For other company-related programs or services, including but not limited to administering our drug-free workplace program, coordinating business-related travel, or allowing use of company-owned automobiles To provide, support, and improve our website and services relating to your employment or potential employment For internal business purposes
Identifiers Other PI Sensitive Characteristics Commercial Geolocation Sensory Professional Education Inferences	To administer payroll, payment of expenses, and other employee benefits, such as leave of absence, employee wellness programs, retirement plans, medical insurance, education reimbursement, or bonuses To confirm your eligibility for employment or other professional engagement, such as conducting a background check, obtaining a consumer report or investigative consumer report about you, verifying your identity, and confirming your authorization to work in the US
Identifiers Other PI Sensitive Characteristics (if provided) Internet Activity Sensory Professional Education Inferences	For recruitment, promotion, job transfer, processing your job application, and assessing your candidacy for employment or other professional engagement with us
Identifiers Other PI Sensitive Internet Activity Geolocation Sensory Professional Education Inferences	To evaluate your performance as an employee or other professional engagement with us
Identifiers Other PI Commercial Internet Activity Sensory Professional Inferences	To provide you with information about products or services from business partners that we think may be of interest to you
Biometric	For certain positions within the organization, in order to fulfill regulatory obligations, we may be required to collect your fingerprints and provide them to our regulators and other third parties

Sources of Personal Information

Category of Personal Information	Sources
All Categories except Biometric	Directly and indirectly from activity on our website (www.gaig.com), other Great American Insurance Group member websites, intranet, or mobile apps. For example, from submissions you make, when you access our portals, and/or from website details collected automatically when you access our website. From third parties that interact with us or support us. For example, from recruiters, service providers who assist us with providing or improving our services, service providers who assist us with fraud detection or compliance with government regulations or laws, or government agencies. Indirectly. For example, from information provided by an agent or supplier of yours.
All Categories except Inferences	Directly from you. For example, from forms you complete and/or information you request.
Identifiers and Internet Activity	Through tracking technologies when you access and use our website, including cookies, browser fingerprinting, and location identifying technologies. See our Cookie Policy on www.gaig.com for more information on how we use cookies.

Third Parties to Whom Personal Information is Disclosed

Category of Personal Information	Third Parties
All Categories	Our affiliates or pursuant to a business transfer Government agencies or to protect the rights of our Company or others Pursuant to a legal request or subpoena Third parties who assist with any of the above Other third parties at your direction
All Categories except Biometric	Our service providers
Identifiers and Internet Activity	When you interact with third-party content on our website

Sale and Retention of Personal Information

We do not sell your personal information. We retain your personal information for at least as long as is reasonable or necessary to fulfill the purposes for which the data was collected, to meet our business requirements, and to comply with applicable laws and regulations.

Changes to this Privacy Notice

This Privacy Notice may be changed from time to time. The date noted on the Privacy Notice indicates when it was last revised.

Contact Information

If you have questions about this notice, please contact us at:
Phone: 800-545-4269
Email: clegal@gaig.com

This Privacy Notice is not a contract for employment and does not alter the employment ‎at-will relationship between us and any employee