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CALIFORNIA EMPLOYEE PRIVACY POLICY

Effective Date: January 5, 2023

This policy describes how J.D. Power (the “Company”) collects, uses, and shares information of its employees, job applicants, contractors, officers, directors or owners who are California residents and are subject to the California Consumer Privacy Act of 2018 as replaced by the California Privacy Rights Act (“CCPA”). If you have questions about our Privacy Policy or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section below.

APPLICABILITY

This privacy policy does not apply to personal information collected about you as a consumer outside the employment context. Our privacy policy posted to our website at jdpower.com/privacy and our California supplement posted at jdpower.com/privacy/california applies to website visitors. Additionally, some of our websites and services have separate privacy policies and terms of use that apply to their use. Please review those policies and terms regarding personal information collected about you outside the employment context.

INFORMATION WE COLLECT

The information we collect about you is primarily information you provide when you initially apply for a position and join the Company, supplemented by information generated in the course of your employment. We collect and, in the past 12 months have collected, the following categories of personal information enumerated in the CCPA:

  • Identifiers, including name, postal address, email address, telephone number, emergency contact information, device identifier and unique personal identifier.
  • Internet Activity, including browsing and search history on our computer or mobile devices, and interactions with our websites or mobile applications.
  • Non precise geolocation data, including location derived from an IP address through our computer or mobile devices.
  • Professional and Education History, including CV or resume, qualifications, work experience, compensation history where permissible under applicable law, language abilities, areas of expertise, education and training history, professional membership, awards and prizes, references, criminal record and background checks information.
  • Employment Information, including job title, date of commencement of employment, working hours, electronic corporate device tag or registration numbers, employee number, photograph, performance reviews, records of roles performed and applied for, appraisal and evaluation records, disciplinary and accident information, compensation, incentive details, special work environment requests, life insurance beneficiary designations, government forms and records in relation to employment and related taxes and job profile.

In addition, we collect, and in the past 12 months have collected, the following categories of sensitive personal information:

  • Sensitive identifiers, including your social security number and government issued identification (such as driver’s license number or passport number).
  • Financial Information, including bank account number and pension details (for payroll and pension contributions).
  • Health Information, including health and dental insurance policy number, details about spouses and dependents, absences from work, disability information, allergies and intolerances, medical and ongoing health conditions. This may also include self-reported health screening questionnaires, test result information regarding your COVID-19 status, and other information as necessary to help ensure the safety of our employees who are working in our offices.
  • Protected Classes, including information about your race, age, gender, sex, citizenship status (evidence of the right to work), nationality, medical conditions and disabilities (physical or mental to provide assistance), marital status and veteran status.

INFORMATION USE AND DISCLOSURE

We use your personal information for internal lawful manners compatible with the context you provided the information and in accordance with this California Employee Privacy Policy. The following are business purposes for which the Company uses your information:

  • For operational purposes related to your employment.For example, we process your information for Human Resources and records management and related administration as well as to:
    • evaluate your qualifications for employment,
    • provide you access to our network, applications and other services,
    • pay you, administer salaries, and provide other employment benefits including those set out in our handbooks or policies,
    • assist with budgeting,
    • develop business contact directories,
    • assess and monitor your compliance with Company policies and procedures,
    • conduct performance evaluation and appraisals,
    • notify you about changes to your employment; and
    • implement measures to protect our systems and networks and prevent unauthorized access.
  • To comply with legal obligations. For example, we use your personal information to calculate taxes and pay wages, provide employment benefits, assist with immigration services, comply with legal requests such as subpoenas or court orders, or prosecute or defend a lawsuit, arbitration, or similar proceeding.
  • To improve our operations. For example, we analyze trends and usage such as the efficiency of deliveries and store operations.
  • Fulfilling requests by you or with your consent. For example, if you request we share your information with other parties we may do so to fulfill your request.

We disclose the personal information to the following categories of persons:

  • Service providers and contractors that process personal information on our behalf pursuant to a written contract.
  • To law enforcement and other third parties to address legal obligations.
  • To third parties in connection with, or during negotiations of, any proposed or actual merger, purchase, sale, or any other type of acquisition.
  • To third parties at your direction to fulfill requests by you or with your consent.
  • We collect, use, and disclose sensitive personal information as necessary to perform services reasonably expected by an average consumer in the course of employment, and for other permissible purposes under CCPA.
  • We do not “sell” or “share” your personal information as those terms are defined by the CCPA.

RIGHT TO KNOW, CORRECT, AND DELETE

You have the right to know certain details about our data practices with respect to your personal information. In particular, you may request the following form us:

  • The categories of personal information we have collected about you,
  • The categories of sources from which the personal information was collected,
  • The categories of personal information about you we disclosed for a business purpose or sold or shared,
  • The categories of persons to whom the personal information was disclosed for a business purpose or sold or shared,
  • The business or commercial purpose for collecting or selling or sharing the personal information, and
  • The specific pieces of personal information we have collected about you.

Unless you specify otherwise, the response we provide will cover the 12-month period preceding our receipt of the request. Starting with personal information collected on or after January 1, 2022, you may request that we disclose details beyond the 12-month period, and we shall do so unless doing so proves impossible or would involve a disproportionate effort. In addition, you have the right to correct or delete the personal information we have collected from you. These rights also apply to sensitive personal information. You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly. You have the right not to receive discriminatory treatment by us for the exercise of any your rights. To exercise any of these rights, please contact the Human Resources Department as set out in the “Contact Us” section below, and specify which right you are seeking to exercise. Please note that your rights may be limited due to various exceptions and exemptions, including as required for us to comply with employment law.

INFORMATION SECURITY

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

RETENTION

We retain each category of personal information, including sensitive personal information, in accordance with our HR records retention policy for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify or supplement this policy at any time. If a material change to the terms of this policy is made, the HR Department will provide notice of the changes.

CONTACT US

If you have any questions about our data practices, wish to exercise your rights, or experience any difficulty accessing the information in this Privacy Policy, please contact the HR Department:

By email: [email protected]

By mail:

Human Resources

J.D. Power

320 East Big Beaver Road, Suite 500

Troy, MI 48083