It is the philosophy of The Company to safeguard personal employee information in its possession to ensure the confidentiality of the information. Additionally, The Company will only collect personal information that is required to pursue its business operations and to comply with government reporting and disclosure requirements.

Personal information collected by The Company may include employee names, addresses, telephone numbers, e-mail addresses, emergency contact information, EEO data, social security numbers, date of birth, employment eligibility data, benefits plan enrollment information, which may include dependent personal information, and school/college or certification credentials, as well as background information necessary to obtain required security clearances.

All pre-employment inquiry information and reference checking records conducted on employees and former employee files are maintained in locked, segregated areas and are not used by The Company in the course of its business operations.

Personal employee information will be considered confidential and as such will be shared only as required and with those who have a need to have access to such information – such as human resource, payroll, and accounting staff. All hard copy records will be maintained in locked, secure areas with access limited to those who have a need for such access. Personal employee information used in business system applications will be safeguarded under Company proprietary electronic transmission and intranet policies and security systems. Participants in The Company benefit plans should be aware that personal information will be shared with plan providers as required for their claims handling or record keeping needs.

Company-assigned information, which may include organizational charts, department titles and staff charts, job titles, department budgets, Company coding and recording systems, telephone directories, e-mail lists, Company facility or location information and addresses, is considered by the Company to be proprietary Company information to be used for internal purposes only. The Company maintains the right to communicate and distribute such Company information as it deems necessary to conduct business operations.

If an employee becomes aware of a material breach in maintaining the confidentiality of his or her personal information, the employee should report the incident to HR. Any suspicion of breach of confidential information will be investigated and if valid, corrective action will be taken. Please be aware that a standard of reasonableness will apply in these circumstances.

Examples of the release of personal employee information that will not be considered a breach include the following:

• Release of employee birth dates is not considered confidential and will be shared with others who may elect to recognize employees on such dates.
• Personal telephone numbers or e-mail addresses may be distributed to department managers and others in order to facilitate Company work schedules or business operations and to facilitate the closing of the offices and job sites during periods of inclement weather or for any other reason. • Employee identifier information used in salary or budget planning, review processes and for timekeeping purposes will be shared with managers.
• Employee’s Company anniversary or service recognition information will be distributed to appropriate personnel that need the information to facilitate the celebration of such events.

Employee and dependent information may be distributed in accordance with open enrollment processes for periodic benefit plan purposes.