Hachette Book Group’s Employee, Independent Contractor, and Job Applicant Privacy Policy

HACHETTE BOOK GROUP’S EMPLOYEE, INDEPENDENT CONTRACTOR, AND JOB APPLICANT PRIVACY POLICY

Effective Date: January 1, 2023
Last Updated: January 1, 2023

Hachette Book Group, Inc. (“Hachette” or “we”) collects a variety of personal information from our employees, independent contractors, and job applicants (individually or collectively, as applicable, “you”), as further described in this Employee, Independent Contractor, and Job Applicant Privacy Policy (the “Policy”). We understand that you care about how we collect, use, and share your personal information and value the trust you place in us. This Policy explains:

• • The categories of personal information that we collect from or about you.

• • The sources from where we collect your personal information.

• • The purposes for which we use your personal information.

• • Who we share your personal information with, and under what circumstances.

• • How long we retain your personal information.

This Policy also contains specific disclosures that only apply to California residents (the “California Notice at Collection”).

Please note that your interactions with our public-facing websites, social media sites and handles, email newsletters and communications, and other online services (“Services”) are governed by our general privacy policy. This Policy does not apply to non-Hachette websites and mobile applications that may be linked to or from any communications or other interactions that we have with you. Please review the privacy policies on those websites and applications directly to understand their privacy practices.

Please note that we are providing this Policy to all employees, independent contractors, and job applicants. This Policy does not determine or demonstrate the employment status or classification of any particular person to whom it is provided.

Categories of Personal Information We Collect

“Personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual. It does not include data that cannot be associated with you or for which identifying elements have been removed (“de-identified information”).

We collect the following categories of personal information from or about you and have collected each of the following categories in the past twelve months:

• • Personal identifiers. This category may include:
  • –  Personal contact and job-related details, such as name, title, and contact information (i.e., phone numbers, email addresses, and current and former postal addresses).

   

  • –  Financial information that you provide to us, such as your bank account details, information for payroll records, and tax status information.

   

  • –  Social Security number, marital status, and information about your dependents.

   

  • –  Date of birth, gender, driver’s license, number, nationality/visa status, and passport numbers.

   

• • Health and biometric information. This category may include:
  • –  Medical conditions and health and sickness records when you report this information to us, including details of any absences (other than holidays) from work, such as time on statutory parental leave and sick leave.

   

  • –  Information related to biological screenings or testing for controlled substances.

   

  • –  Records related to administering and maintaining your healthcare and other benefits.

   

  • – Information about a condition needed for pension and permanent health insurance purposes when you leave employment at Hachette and the reason for leaving is related to such condition.

   

• • Protected classifications. This category may include:
  •  –  Date of birth, gender, marital status, and information about your dependents.

   

  • –  Information about your racial and/or ethnic origin, gender, gender identity, gender expression, sexual orientation, veteran status, and/or disability status, if you choose to provide such information to us.

   

• • Internet or other electronic network activity information. This category may include:
  • –  Information about your use of our computers and networks, including your use of the Internet and your email communications using our computers, systems, applications, hardware, content, and resources.

   

  • –  Internet-based information that you use, generate, or access on our computers, networks, and devices.

   

  • –  Your image, as captured from time to time by our closed-circuit cameras, which create video records of our offices.

   

  • –  Records of your use of any access badges issued to you.

   

• • Geolocation data. This category may include:
  • –  Information about your location if you are operating a company-issued vehicle or device, such as a company-issued mobile phone, as part of the fulfillment of your employment duties.

   

• • Audio, electronic, visual, thermal, olfactory, or similar information. This category may include:
  • – Photographs and/or recordings of you on building security cameras.

   

  • – Recordings of your telephone calls when you access company resources, such as information technology services.

   

• • Professional or employment-related information. This category may include:
  • –  Information about your professional and employment-related background through the recruitment and employment application processes (including copies of right to work documentation, references, and other information included in a resume or cover letter as part of your application).
  • –  Information captured in background checks.
  • –  Information you provided during the employment application process, such as your work history, start and separation dates, training records, professional memberships, and salary history.
  • –  Information regarding your salary, annual leave, retirement, work performance, disciplinary actions, grievance information, job titles, work history, working hours, holidays, absences, training records, and professional memberships.

   

• • Education information. This category may include:
  • – Information that you provided during the employment application process about the educational institutions that you have attended or your level of education.

   

  • – Information about any professional licenses that you hold, certifications that you receive, or additional education or training that you undertake during your employment.

   

• • Inferences drawn from any of the foregoing examples of personal information to create a profile about you, reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
• • Sensitive personal information. This category may include:
  • – Social Security, driver’s license, state identification card, or passport number.

   

  • – Information about your racial and/or ethnic origin or religious or philosophical beliefs, if you choose to provide such information to us.

   

  • – Any information resulting from the processing of biometric information to identify you.

   

  • – Information regarding your health.

   

  • – Information regarding your sex life or sexual orientation, if you choose to provide such information to us.

   

Please note that some personal information may fall within more than one category. Not every category or example of personal information that we have identified in this Policy will apply to every employee, independent contractor, or job applicant from whom we collect personal information.

Sources of Personal Information

We collect personal information about you through the application and recruitment process, directly from you, employment agencies, and screening services or other background-check providers. We may collect additional information from third parties, including former employers, credit reference agencies, or other sources that supply employment verification services. We also collect personal information about you during your employment with us or the provision of your services to us. This can be in the form of information that you provide directly to us, information that we gather from outside parties, or information that we collect automatically about you, such as by monitoring your use of and access to company vehicles and computers.

When you interact with our Services, certain information about your use of those Services is collected automatically. Much of this information is collected through cookies, web beacons, and other tracking technologies, as well as through your web browser or device. For more information, please review Hachette’s general privacy policy, which covers this topic in greater detail.

Purposes for Using Your Personal Information

We may use the personal information that we collect from or about you, including your sensitive personal information, for the following purposes:

• • To make decisions related to your employment or provision of services to us or notify you of future opportunities at Hachette.

• • To administer payments and benefits.

• • For our business purposes, including:
  • – Conducting data analytics studies to review and better understand employee retention and attrition rates.

   

  • – Ascertaining and fulfilling education, training, and development requirements.

   

  • – Maintaining your records in accordance with internal record retention requirements.

   

  • – Communicating company-wide business matters and important announcements.

   

  • – Maintaining a company directory on our intranet.

   

  • – Providing information technology support to you in the ordinary course of business.

   

  • – Processing expense reports and booking work-related travel.

   

• • To investigate complaints, grievances, and violations of Hachette policies.

• • To enact security measures, communicate with emergency contracts, and comply with health and safety obligations.

• • To comply with legal obligations.

• • To foster diversity, inclusion, and a welcoming work culture.

Who We Share Your Personal Information With

We may share your personal information with the following parties for the following purposes:

• • To service providers, which are companies that we use to transmit, collect, process, or store information for us, and who are required to treat the information that we share with them as confidential. Service providers may use information that we share with them only for the services they provide to us and purposes for which we disclose it to them. The categories of service providers with whom we share information and the services that they provide to us are:
  • – Payroll service providers that assist us in calculating and disbursing your salary, payments, and other compensation.

   

  • – Auditing and accounting firms, such as firms that assist us in the creation of our financial records.

   

  • – Professional services consultants, such as firms that perform analytics, assist with improving our business, provide legal services, or supply project-based resources and assistance.

   

  • – Recruitment vendors that assist with the application process, including assessing job applicant qualifications and providing the platform through which job applicants submit their candidacy.

   

  • – Analytics services, such as entities that analyze traffic to and on our website and assist with identifying and communicating with potential customers.

   

  • – Security vendors, such as entities that assist with security incident verification responses, service notifications, and fraud prevention.

   

  • – Information technology vendors, such as entities that assist with website design, hosting, and maintenance, data and software storage, and network operations.

• • To third parties when required by law or to protect Hachette or other persons.

• • When you choose to enroll in certain employee benefit programs, to third parties with whom we have contracted to provide benefits to you. This disclosure is done at your direction and involves the information necessary for you to enroll yourself or your dependents in benefit programs. These third parties may collect additional information about you or your dependents in connection with providing benefits and may use and share that information in ways outlined in their own privacy policies.

• • To third parties in the event of a merger or some other corporate event that modifies the structure and organization of Hachette. Please note that we cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Policy.

• • To third parties where you have provided your consent.

We do not sell the personal information that we collect from and about you.

Personal Information Retention Periods

Your personal information will be stored in accordance with applicable laws and kept as long as Hachette has an ongoing legitimate business need to carry out the purposes described in this Policy or otherwise required by applicable law.

California Notice at Collection

The provisions of this California Notice at Collection apply only to residents of California and in addition to the general information regarding how we collect, use, and share your personal information, as detailed in the preceding provisions of this Policy. Persons with disabilities may contact us at privacy@hbgusa.com or 1-800-890-0625 to obtain this California Notice at Collection in an alternative format.

Under the California Consumer Privacy Act (the “CCPA”), we must notify you:

• •  Of the categories of personal information that we collect from and about you and the purposes for which such personal information may be used. For a list of the categories of personal information that we collect from and about you and have collected in the past twelve months, please see the section in this Policy titled “Categories of Personal Information We Collect”. For a list of the purposes for which we may use your personal information, please see the section in this Policy titled “Purposes for Using Your Personal Information”.

• •  Of the categories of sensitive personal information that we collect from and about you and the purposes for which such sensitive personal information may be used. For a list of the categories of sensitive personal information that we collect from and about you and have collected in the past twelve months, please see the section in this Policy titled “Sensitive Personal Information”. For a list of the purposes for which we may use your sensitive personal information, please see the Section in this Policy titled “Purposes for Using Your Personal Information”.

• •  If your personal information is sold or shared for cross-context behavioral advertising. Please note that we currently do not sell your personal information, nor do we share it with third parties for the purpose of cross-context behavioral advertising.

• •  Of the length of time that we intend to retain each category of personal information that we collect from and about you. For information on Hachette’s personal information retention periods, please see the section in the Policy titled “Personal Information Retention Periods”.

To the extent that we collect any personal information from or about you that is subject to the CCPA, your rights are described below. Please note that certain information that we collect may be exempt from the CCPA because it is considered public information (i.e., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm-Leach-Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.

• • Right to Request Deletion of Information. You have the right in certain circumstances to request that we delete personal information that we have collected directly from you. You may submit such a request by following the instructions provided in Hachette’s general privacy policy, as described in the provision titled “How to Submit a Request” under the section titled “Your California Privacy Rights”. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless retention of the personal information is:
  • – Necessary to provide benefits or services that you have requested.
  • – Necessary to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity and/or prosecute those responsible for that activity, or ensure the physical safety of natural persons.
  • – Reasonably anticipated within the context of your employment, engagement, or application for employment with us.
  • – For solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
  • – Necessary to comply with a legal obligation.

• • Right to Correct. You have the right to request the correction of any personal information that we maintain about you.

• • Right to Know/Access Information. You have the right to request access to personal information collected from or about you over the past twelve months and information regarding the source of that personal information, the purposes for which we collect it, and the service providers and third parties with whom we share it. You may submit such a request by following the instructions provided in Hachette’s general privacy policy, as described in the provision titled “How to Submit a Request” under the section titled “Your California Privacy Rights”. Once we receive and confirm your verifiable consumer request, we will disclose such information.

• • Right to Opt Out of Sale of Personal Information to Third Parties. The CCPA defines “selling” personal information as disclosing it to a third party for monetary or other benefit. You have the right to opt out of any sale of your personal information by Hachette to third parties. However, we currently do not sell your personal information to any third parties. Please note that your right to opt out does not apply to our sharing of your personal information with service providers.

• • Right to Limit the Use or Disclosure of Sensitive Personal Information. You have the right to limit the use or disclosure of your sensitive personal information if we are using your sensitive personal information beyond what is reasonable and proportionate within the context of your relationship with us as an employee, independent contractor, or job applicant. You can make a request for us to limit the use or disclosure of your sensitive personal information by emailing us at privacy@hbgusa.com.

• • Right to Non-Discrimination. You have the right for us not to discriminate against you for the exercise of your rights under the CCPA.

Changes to This Policy

We may make changes to this Policy from time to time. We will post any changes here, and such changes will become effective when they are posted. In such cases, we will indicate at the top of this Policy when it was last updated. If we make a material change to this Policy, we will attempt to notify you, as required by law.

Contact Details

Hachette Book Group, Inc.
1290 Avenue of the Americas
New York, NY 10104
Attention: Andrea Weinzimer, Senior Vice President, Human Resources
With a copy to: Min Lee, General Counsel