We obtain personal information about you from the following categories of sources:

• Directly from you during your candidacy for a position, your employment with us, or when you enroll in benefits programs.
• Job boards and websites you use to apply for a job with us.
• Employment agencies and recruiters.
• Providers of various services, including providers we make available to our employees as part of our benefits programs.
• Professional references you authorize us to contact.
• Prior employers that provide employment references.
• Social media networks.
• Background check services.
• Publicly available sources.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• Facilitate, fulfill or meet the reason for which you provided the information.
• Establish and maintain communications with you.
• Evaluate qualifications for employment.
• Perform background checks and verify past employment, educational history, professional standing, and other qualifications.
• Determine physical and mental fitness for work.
• Administer health, dental, retirement and other benefits.
• Payroll, compensation, retirement and benefits programs.
• Travel and expense processing.
• Provide access to facilities and systems.
• Review and evaluate work performance.
• Create staff directories.
• Manage attendance, absences, leaves of absence and vacations.
• Career management, training and development.
• Manage internal complaints, disciplinary matters, grievances and termination.
• Conduct investigations including investigations of suspected misconduct or non-performance of duties.
• Workforce planning, recruitment, staffing and budgeting.
• Manage workers’ compensation claims.
• Business management, operation activities, strategic planning and project management.
• Administer information systems, networks, servers, databases, websites, applications, hardware, software and communications systems.
• Audits, recordkeeping and reporting obligations.
• Facilitate or complete actual or prospective business transactions.
• Improve company products and services.
• Protect the health and safety of our staff and others, and maintain the security and integrity of our systems, assets and facilities.
• Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity.
• Engage in legitimate business purposes reasonably required for our operations and services.
• Comply with legal, regulatory, financial and accounting obligations, and company policies and procedures.
• Respond to requests from the government, law enforcement or other authorities.
• Respond to legal processes, lawsuits, claims, subpoenas, complaints and court orders, pursue legal rights and remedies, and defend or prosecute litigation, legal rights, claims and allegations.

Sharing of Personal Information

We do not sell personal information, including any sensitive personal information, we collect about you or share it with third parties for cross-context behavioral advertising.

We may share your personal information with the following categories of third parties:

• Services providers and vendors, including payroll, benefits, background checks, legal, tax, accounting, IT and business services.
• Third parties to complete business transactions or the business purposes discussed above.
• Law enforcement, regulators, and other parties for legal reasons, as required by law or subpoenas, or if we believe such actions are necessary to comply with the law and the requests of regulators, law enforcement or other public authorities, or to protect our or others safety, rights or property, or to investigate fraud or protect the security or integrity of our products and services.
• Other parties with your consent or at your direction.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

• Category A: Identifiers.
• Category B: California Customer Records personal information categories.
• Category C: Protected classification characteristics under California or federal law.
• Category D: Commercial information.
• Category E: Biometric information.
• Category F: Internet or other similar network activity.
• Category H: Sensory data.
• Category I: Professional or employment information.
• Category K: Inferences drawn from other personal information.
• Category L: Sensitive personal information.

Retention of Personal Information

We retain personal information for as long as necessary or permitted for the purposes described in this notice or otherwise authorized by law, including satisfying any legal, accounting, regulatory, reporting or business requirements, establishing or defending legal claims, and satisfying record retention requirements.

Your Rights and Choices

The CCPA provides you with specific rights regarding your personal information. However, these rights are not absolute and are subject to certain exceptions. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive your request and verify your identity, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources from which the personal information is collected.
• Our business or commercial purpose for collecting that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you.

Right to Delete

You have the right to request that we delete certain personal information that we collected from you. However, this does not apply to any personal information exempt under the CCPA. Once we receive your request and verify your identity, we will delete any personal information in our records that is not subject to any of the CCPA exemptions.

Right to Correct

You have the right to request that we correct your personal information if you believe it is inaccurate. Once we receive your request and verify your identity, we will correct any inaccurate personal information that we have collected about you that is not subject to any of the CCPA exemptions.

Right to Opt Out

You have the right to opt out of the sale of your personal information or the sharing of your personal information for cross-context behavioral advertising. However, we do not sell your personal information or share your personal information for cross-context behavioral advertising.

Right to Limit

You have the right to limit the use and disclosure of your sensitive personal information. However, we do not use or disclose sensitive personal information for purposes other than the specifically permitted purposes.

Right to Non-Discriminate

You have the right not to receive discriminatory treatment by us for the exercise of your CCPA rights.

Exercising Your CCPA Rights

To exercise the rights described above, please submit a verifiable request to us by either:

• Calling the Human Resources Department at 800-234-2103
• Emailing us at [email protected]

Only you, or someone legally authorized to act on your behalf, may make a verifiable request related to your personal information.

You may only make a verifiable request for access or data portability twice within a 12-month period. The verifiable request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days and endeavor to respond within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Contact Information

If you have any questions or comments about this notice, please contact us at:

• Phone: 800-234-2103
• Email: [email protected]

Postal Address

Western Mutual Insurance Group
Attn: Privacy Officer
PO Box 19626
Irvine, CA 92623-9626

Download our California Privacy Rights Request Form here.

Last Updated August 1, 2024