Employment Policies.

effective as of January 1st, 2023.

1.0 Introduction

In this Applicant and Employee Privacy Notice ("Notice"), Santa Fe describe the types of information that we collect from job applicants and current and former employees, how we use that information, and how we may share that information.

This Notice does not form a part of any contract of employment offered to job applicants hired by Santa Fe. Provisions of this Notice dealing with individuals employed with Santa Fe are not applicable until they begin working for us.

We may change this Notice from time to time, and we will post changes in an area of our website that is accessible to current and former Santa Fe employees.

2.0 Categories of Personal Information We Collect

We may collect a range of Personal Information. “Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you. We collect the following types of Personal Information when you apply for a job with Santa Fe or during the course of your employment at Santa Fe:

  • Your name, address, email address, telephone number, and other contact information;

  • Your resume or CV, cover letter, previous and/or relevant work experience, or other experience, education, transcripts, or other information you provide to us in support of an application and/or the application and recruitment process;

  • Information from interviews you may have, if any;

  • Details of the type of employment you are looking for, current and/or desired salary, other terms relating to compensation and benefits packages, and job preferences;

  • Details of how you heard about the position you are applying for;

  • Any sensitive and/or demographic information obtained during the hiring process such as Social Security number, gender, information about your citizenship and/or nationality, medical or health information, and/or your racial or ethnic origin;

  • Reference information and/or information received from background checks (as applicable), including information provided by third parties;

  • Information relating to any previous applications you may have submitted to Santa Fe and/or any previous employment history with Santa Fe;

  • Information about your educational and professional background from publicly available sources that we believe is relevant to your application or a potential future application (e.g., your LinkedIn profile);

  • Banking information for direct deposit purposes, income history, income information, benefits information, and information regarding your beneficiaries;

3.0 Information Collected From Other Sources

We obtain information about individuals from various third-party and public sources, and we may combine that data with Personal Information we have. For example:

  • Santa Fe may collect application information from recruiters;

  • Santa Fe may collect information regarding your past employment (including performance information) from former employers;

  • Santa Fe may collect information regarding your citizenship or eligibility to work in the country where you would be employed from government agencies;

  • Santa Fe may collect your credit history and/or criminal record if you consent to a credit check or background check;

  • Santa Fe may collect information relating to your qualifications to work with Santa Fe from your references;

  • Santa Fe will collect tax related information from the Internal Revenue Service.

4.0 Children Under 18

We only employ those who are legally eligible to work at the location of employment, which is typically the age of majority (18 years old). Please do not send us application materials if you are under the legal age eligible for employment.

5.0 Purposes for Which We Collect Personal Information

Santa Fe processes your Personal Information as described in this Notice for the following purposes:

  • To manage the application process. We use your Personal Information to process your job application, verify the information you have provided in your application, communicate with you regarding your application, answer your questions regarding the application process, and confirm your eligibility for a position. We may also save your information for future job openings within Santa Fe.

  • To manage the hiring process. We may use your Personal Information in the hiring process to conduct interviews. We may also use your Personal Information to perform background and reference checks—with your consent—if you are offered a position.

  • To communicate with you. We may use your Personal Information to provide information to you, respond to your questions, notify you of changes to your compensation and benefits program, or notify you of emergencies.

  • To manage the onboarding process. Upon being hired by Santa Fe, we will collect Personal Information when you complete new hire paperwork to assist us in administering salary and benefits and to assist us with complying with governmental and legal requirements.

  • To administer compensation and benefits programs. We will use the Personal Information you provide to process payroll, pay taxes, help employees address employment-related tax issues, administer benefits, and handle work-related expense reimbursements. We may also use this Personal Information to manage requests for accommodation requests. We also use this to administer employee claims such as workers’ compensation or unemployment benefits.

  • For performance management. Santa Fe collects Personal Information in order to assess your performance, assist in career development, conduct pay and grading reviews, and to handle any employment-related disputes. We may also use Personal Information to respond to violations of company policies and gather information for disciplinary actions. We may monitor any activity you perform online while using a Santa Fe device or while connected to Santa Fe internet such as monitoring the websites you visit and your activity on those websites.

  • Educational and professional services. We may use your Personal Information to assist with education, training, and professional development.

  • Law enforcement and courts. We may disclose your Personal Information in response to a subpoena, a search warrant, or other legally valid process. We may use your Personal Information to cooperate with law enforcement or other government entities if you are suspected of having violated applicable laws.

  • Recordkeeping. We may use Personal Information to comply with applicable legally required or industry standard business and employment recordkeeping requirements and to respond to governmental requests for information.

  • Health and safetyWe use Personal Information to protect your health and safety or the health and safety of others, including the use of technology to allow contact tracing if you may have been exposed to communicable diseases such as COVID-19. We may also use this information to respond to an employee-related emergency. We also use this Personal Information to protect our facilities and personal property.

  • Protect our legal rights. We may use your Personal Information to protect our legal rights, defend a claim or lawsuit, and investigate or prevent actual or suspected loss or harm to persons or property. We may use your Personal Information to seek legal, accounting, or other professional advice. When necessary to identify, contact, or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Santa Fe or any other party.

  • Security. We may use your Personal Information to monitor the use of our information systems and electronic resources, to conduct internal audits or investigations, and for the safety and security of Santa Fe employees, visitors, and facilities. We also may use such information to protect Santa Fe against illegal activity and misconduct such as fraud, deceptive practices, and security investigations. We use this to offer, operate, maintain, deliver, troubleshoot, and update the Site, programs, network, and systems used by Santa Fe in the course of its business.

6.0 How We Share Your Personal Information

We may share your personal information in the following circumstances:

  • Legal requirements. We will cooperate with law enforcement and other governmental agencies. We may disclose Personal Information for the following legal purposes:

o If we believe in good faith we are legally required to disclose that Personal Information.

o If we are advised to disclose Personal Information by our legal counsel.

o When necessary to identify, contact, or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Santa Fe or any other party.

o For tax and payment purpose (e.g., Internal Revenue Service).

o To protect our rights or property, your health and safety, or the health and safety of others.

o To detect and investigate fraud or illegal activity or to respond to a government request.

o To respond to an emergency.

  • Professional advisors. We may share Personal Information with our professional advisors, such as our attorneys and accountants, in their capacity as advisors, including for advice on potential or actual litigation matters.

  • Change in ownership. We may use and disclose Personal Information in connection with the evaluation of a change of control of Santa Fe such as in the event of a merger, acquisition, or sale of assets. We may provide Personal Information in connection with a due diligence process, or it could be transferred as part of the change in control to subsequent owner(s). If we (or our assets) are acquired or if we go out of business, enter bankruptcy, or go through some other change in control or reorganization, Personal Information and other information could be one of the assets transferred to or acquired by a third party or reviewed as part of the due diligence process.

7.0 Retention of Your Personal Information

Personal Information will be stored in accordance with applicable laws and kept as long as needed to carry out the purposes described in this Notice or as otherwise required by applicable law, taking into consideration any statutorily required minimum periods of time in applicable jurisdictions. Generally, this means your Personal Information will be retained until the end or your employment or work relationship with us plus a reasonable period of time thereafter to respond to employment or work-related inquiries or to deal with any legal matters, document the proper termination of your employment or work relationship, or to provide you with any ongoing benefits.

Personal Information which is no longer to be retained will be securely and effectively destroyed or permanently erased from our systems, and we will also require third parties to destroy or erase such Personal Information where applicable.

8.0 Non-Discrimination

We will not discriminate against you in the event you exercise any of the aforementioned rights under NYPA as written by NY.GOV.

9.0 Changes to this Notice

We may change this Notice from time to time, and we will post any changes on this page. Each version of this Notice is identified at the top of the page by its Effective Date.

10.0 Contact Us

For any questions or concerns, please contact us as follows:

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