Brookwood® Employee Privacy Policy

This policy (“Policy”) summarizes Brookwood Companies Incorporated and its subsidiaries, including but not limited to Kenyon Industries, Inc. d/b/a Brookwood Finishing, Brookwood Laminating, Inc., and Swan Dyeing and Printing Corporation, (hereinafter “Company”) policies and procedures regarding collection, processing, and use of prospective, current, and former employees’ personal information (“HR Data”). Company reserves the right to change this Policy at any time, and Company will communicate such changes in accordance with applicable law.

What HR Data does Company collect?

Company collects information from prospective, current and former employees, as necessary and appropriate, to carry out legitimate employment purposes. Company collects the following types of HR Data:

• Personal contact details (name, email address, home address, phone number, etc.)
• Date of birth
• Employment history and records (including references, work history and proof of work eligibility)
• Government identification numbers such as social security number, social insurance or other national insurance number, driver’s license number or other identification card number
• Bank account details and payroll information
• Salary and benefits information including martial and dependent status as needed to administer benefits
• Education and training history
• Race or ethnic origin for work permit purposes
• Criminal history or background check
• Other personal details included in a resume or CV or cover letter or that you otherwise voluntarily provide to us
• Beneficiary and emergency contact information
• Expense information and travel information
• Job performance information including state data and title
• Information held for health and safety purposes such as physical or mental health condition or disability status, including drug tests
• Video surveillance from CCTV systems
• Information about your use of Company systems, networks and devices

From time to time, Company may be required under certain laws (e.g., health and safety, anti-discrimination) to maintain records that can include sensitive personal information, such as government identifiers, information relating to health, maternity or parental leave, pension and retirement.

How Company uses your HR Data

Company uses HR Data for a wide range of employment purposes, such as:

• Recruitment
• Evaluating applications for employment or promotion
• Employee administration
• Business management and planning
• Payroll and expense reimbursement
• Processing benefit plan enrollment and claims forms
• Paying and reporting applicable taxes and tax-related information to appropriate taxing authorities
• Evaluating your performance and assessing qualifications for a particular job or task
• Improving Company’s employment and hiring practices (e.g., through analyzing compilations of statistical data about the use of Company’s recruitment site)
• Tracking HR Data relating to leaves of absence, including sickness absence data, to comply with employment law
• To ensure employee safety in the workplace and provide appropriate workplace accommodations
• Contacting you in the event of an emergency
• Protecting Company, its employees or the public against injury, theft, legal liability, fraud, abuse or other misconduct
• Protecting network and information security, including preventing unauthorized access to Company’s computer and electronic communications systems and preventing malicious software distribution
• Overseeing proper and appropriate use of Company resources including its IT and computer systems
• Gathering evidence in connection with disciplinary action or termination
• To comply with Company’s legal obligations and in connection with legal claims

Sharing HR Data

Company shares your HR Data with affiliates as part of Company’s regular course of business, reporting activities on Company performance, in the context of a business reorganization or group restructuring, for system maintenance support and hosting of HR Data.
Company may disclose your HR Data to agents and contractors that provide services to us, including insurance and benefits companies, and consultants. Company also may send your HR Data to companies that Company has contracted with to operate various information systems or to process certain transactions (e.g., payroll services providers).

Before disclosing your HR Data to a third party, Company will also take reasonable steps to make sure that the third party subscribes to practices substantially similar to the principles Company follows when handling your HR Data.
Company may also disclose your HR Data for the following additional purposes where permitted or required by applicable law.

• To carry out legitimate employment purposes
• To enable certain benefits or service providers to administer Company benefits or employment-related functions on Company’s behalf
• As necessary to assist law enforcement or, as required by law, in connection with an investigation of illegal or criminal activity or other exigent circumstances
• During emergency situations or where necessary to protect the safety of persons
• To governmental agencies that have a lawful right to receive the information, such as taxing authorities
• To legal counsel, independent accountants, auditors and consultants to carry out certain legal, accounting, auditing, payroll or similar activities
• To address certain individual circumstances with your knowledge and consent (e.g., in connection with work-related travel plans or in the preparation of immigration paperwork on your behalf)
• As necessary and appropriate in connection with the sale of all or a portion of our business
• For additional purposes with your consent where such consent is required by law

All Company employees will generally have access to your business contact information such as name, position, and your business telephone number, postal address and email address.
Notice for monitoring business and private use:

As a reminder, Company may monitor your use of Company information systems and communications systems, including computers, portable and other devices, telephone, email, voicemail, Internet and other communications (collectively, “Company Systems”). For business reasons, and in order to carry out legal obligations in its role as an Company, use of Company Systems, and any personal use of them, may be monitored. There is to be no expectation of privacy by the employee for any such uses.

Company reserves the right to review the contents of messages on any medium or check activity undertaken through Company Systems for the following purposes (this list is not exhaustive):

• To detect, prevent or investigate cyberattacks or other information security incidents, including but not limited to attempts to gain unauthorized access to Company Systems, the introduction of viruses and malware or other violations of Company’s information security policies (websites or communications may be blocked if they are likely to be, or known to be, sources of viruses, malware or other information security vulnerabilities)
• To monitor whether the use of Company Systems is legitimate, lawful and compliant with the our policies
• To find lost messages or to retrieve messages lost due to computer failure or where the employee is absent and it is necessary for the business to continue his/her correspondence on its behalf or retrieve correspondence or documents he/she may have received or created during such absence
• To identify and filter spam messages, which may entail accessing email content
• To assist in the investigation of wrongful acts affecting Company or for which Company may be liable
• As part of any discovery or disclosure exercise or in relation to any possible litigation or investigation affecting Company
• To protect confidential information and trade and business secrets
• To protect personal information of third parties with whom Company does business
• To comply with any legal obligation

The contents of communications and usage information may be disclosed to third parties (including affiliates, regulatory authorities, courts and counterparties in litigation and our or their agents anywhere in the world) where reasonably required by Company and in accordance with applicable data protection laws.

Where evidence of misuse is found Company may undertake a more detailed investigation, involving the examination and disclosure of any monitoring records and interviewing of witnesses or managers involved. If necessary, such information may be handed to law enforcement in connection with a criminal investigation and used by Company in the context of disciplinary actions against any employee, including you, by a court or tribunal.

Security

While no set of privacy and security standards or safeguards is 100% secure, Company takes reasonable precautions to protect HR Data from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Accessing or modifying HR Data

Employees may have access to their HR Data and may be able to correct, amend or delete certain HR Data. Where permitted, access will be provided upon individual request and within a reasonable amount of time. Note that Company’s obligation to provide access is not absolute, and factors such as expense and burden on us can be considered. If your HR Data changes, such as if you move, notify your local Human Resources department so the changes can be updated accordingly. Your rights and our responsibilities concerning HR Data may differ depending on whether you are an applicant or an employee.

To review your HR Data, you may contact:

Retaining HR Data

Company may retain your HR Data as long as necessary and appropriate to comply with applicable legal standards and our policies and procedures. If you are hired as an employee, Company will transfer HR Data Company collects from you as an applicant into personnel and other files as appropriate.

HR Data that are no longer needed are either irreversibly anonymized (and the anonymized information may be retained) or securely destroyed. For details on the length of time for which each category of HR Data is retained, please refer to our Record Retention Policy. Please note that these periods may be extended where reasonably necessary (for example where Company is required to do so by law or by a regulator).

Changes to this Policy

Company reserves the right to amend this Policy from time to time and encourage you to periodically review this Policy.

Questions

If you have any questions or concerns regarding our privacy practices or if you would like to obtain more information about our HR-related information privacy practices, please contact Maria Oster at maria@brookwoodcompanies.com or 212-551-0148.