Vanguard Careers Privacy Notice – California Residents

In accordance with the California Consumer Privacy Act, as amended (“CCPA”), we are providing additional information in this California Applicant Privacy Notice (the “California Notice” or “Notice”) to further describe the personal information that we collect about California job applicants (“California Applicants”). We may provide you with additional notices about our data collection practices that are covered by other laws (e.g., if we conduct a background check or extend an employment offer), as this Notice is limited to covering the requirements of the CCPA. The Notice solely governs the collection, use, disclosure, retention, and transfer of personal information that we collect through the job application process; this Notice does not apply to any other service or website provided by Vanguard.

Unless otherwise noted, the disclosures herein cover our activities in the twelve (12) months preceding the Effective Date, as well as our current practices.

What is personal information?

In this Notice, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

What Personal Information Do We Collect under CCPA?

Generally, we may collect the following categories of personal information (as set forth in the CCPA) about California Applicants:

• Identifiers: Including real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, Social Security number, driver’s license number, passport number, or other similar identifiers.
• Personal Information Described in Cal. Civ. Code § 1798.80(e): Including name, signature, Social Security Number, address, telephone number, passport number, driver’s license or state identification card number, education, employment, credit/ debit card number, and employment history.
• Characteristics of Protected Classifications Under California or Federal Law: Including age, date of birth, gender, race, ancestry, ethnic origin, national origin, citizenship status, sex, gender identity, sexual orientation, marital status, religion, medical condition, disability, veteran status.
• Internet or Other Electronic Network Activity Information: Including browsing history, search history, and information regarding your interaction with an internet website, application, or advertisement.
• Geolocation Data: Including geographic location information inferred from your device IP address.
• Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information: Including CCTV images and photographs, and audio and video recordings (e.g., recorded interviews).
• Professional or Employment Related Information: Including skills, qualifications, work experience, references, recommendations, and other information included in a resume, CV, application form, or cover letter; answers to behavioral or other screening questions in an application or interview; information contained in any personal webpages, social media pages or documents you choose to share with us; information relating to professional licenses, training, disciplinary actions, and membership in professional organizations; information relating to criminal history; and information relating to membership in civic organizations.
• Non-Public Education Information: Including school(s) attended, grades, transcripts, records of attendance, disciplinary records, and other information relating to your secondary and post-secondary education.
• Sensitive Personal Information: Among the categories of personal information we collect about California Applicants are the following categories of sensitive personal information:
  • Social security, driver’s license, state identification card, or passport number;
  • Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
  • Personal information that reveals a consumer’s racial or ethnic origin, religious or philosophical beliefs, health characteristics or union membership.
• Inferences: Including inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Sources of Personal Information

We may collect the above categories of personal information from the following sources:

• Directly from you: For example, during the application process and throughout your interactions with us, including through our website, company forms, and other processes where you submit information to us.
• Automatically when using our electronic systems: For example, we may collect internet or other electronic network activity information when you use our websites, AI chatbot (“Virtual Assistant”), systems, and applications, and we may collect audio/visual information when you interview with us by phone or video.
• Automatically when you visit our offices: For example, security camera footage.
• From service providers that help us run our business: For example, from human resources and information technology vendors, background check agencies, analytics providers, and other service providers or former employer(s).

We may also collect publicly available information about you, including information that is lawfully made available to the general public from federal, state, or local government records.

Use and Disclosure

How Do We Use Personal Information?
We may use the above categories of personal information for the following purposes:

• Management of Job Applications, Recruiting and Hiring. To review, assess, recruit, consider or otherwise manage California Applicants, candidates, and job applications, including:
  • Scheduling and conducting interviews;
  • Identifying candidates, including by working with external recruiters;
  • To provide the AI “virtual assistant” functionality.
  • Reviewing, assessing, and verifying information provided to conduct criminal and background checks, and to otherwise screen or evaluate California Applicants’ qualifications, suitability and relevant characteristics;
  • Extending offers, negotiating the terms of offers, and assessing salary and compensation matters;
  • Satisfying legal and regulatory obligations;
  • Communicating with California Applicants regarding their applications and about other similar position(s) for which they may be interested;
  • Maintaining California Applicant personal information for future consideration;
  • In support of our equal opportunity employment policy and practices.
• Advertising and Marketing. To market and advertise available positions, and further our efforts to recruit talent.
• Security and Monitoring. To monitor and secure our resources, network, premises, and assets, including:
  • Monitoring for, preventing, and investigating suspected or alleged misconduct or violations of work rules;
  • Monitoring for, preventing, investigating, and responding to potential fraud, security, and privacy incidents;
  • Providing and managing access to physical and technical access controls;
  • Monitoring activities, access and use to ensure the security and functioning of our systems and assets;
  • Securing our offices, premises, and physical assets, including through the use of electronic access systems and video monitoring.
• Auditing, reporting corporate governance, and internal operations. Relating to financial, tax and accounting audits, and audits and assessments of our business operations, security controls, financial controls, or compliance with legal obligations, and for other internal business purposes such as administration of our records retention program.
• Mergers and Acquisitions and Other Business Transactions. For purposes of planning, due diligence and implementation of commercial transactions, for example mergers, acquisitions, asset sales or transfers, bankruptcy or reorganization or other similar business transactions.
• Defending and Protecting Rights. In order to protect and defend our rights and interests and those of third parties, including to manage and respond to employee and other legal disputes, to respond to legal claims or disputes, and to otherwise establish, defend or protect our rights or interests, or the rights, interests, health or safety of others, including in the context of anticipated or actual litigation with third parties.
• Compliance with Applicable Legal Obligations. Relating to compliance with applicable legal obligations (such as hiring eligibility, responding to subpoenas and court orders) as well as assessments, reviews and reporting relating to such legal obligations, including under employment and labor laws and regulations, Social Security and tax laws, environmental regulations, workplace safety laws and regulations, and other applicable laws, regulations, opinions and guidance.
• Other Business and Commercial Purposes. In addition, we may use the personal information we collect about Applicants for other purposes including conducting surveys and workforce analytics.

To Whom Do We Disclose Personal Information?

Although we do not sell Applicant personal information in exchange for money, some of the ways in which we share personal information for advertising, analytics, or other purposes may be considered “sales” or “sharing” under the CCPA. The categories of personal information we disclose in ways that may be considered “sales” or “sharing” include: Identifiers, Personal Records, Commercial Information, Internet or Other Electronic Network Activity Information, Geolocation Data, and Inferences. We share these categories of personal information with our digital advertising providers to deliver Vanguard ads that may be of interest to you, to provide certain types of analytics, and in relation to other services supported by third-party cookies on our website. We do not have actual knowledge that we sell or share the personal information of California residents under 16 years of age.

The chart below shows the categories of personal information we have disclosed to our service providers and contractors for a business or commercial purpose during the last 12 months.

Retention of Personal Information

We keep the categories of personal information described above for as long as is necessary for the purposes described in this Notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:

• Your personal information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected it;
• Your personal information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which it was collected;
• Your personal information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case);
• We are otherwise required or permitted to keep your personal information by applicable laws or regulations.

Where your personal information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention practices, please contact us using the contact details below.

California Privacy Rights

If you are a resident of California, you have the right to submit certain requests relating to your personal information as described below. To exercise any of these rights, please select here or call us at 1-844-841-2739. Please note that if you submit a request to know, request to delete or request to correct, you will be asked to log into your account or to provide 2-3 pieces of personal information that we will match against our records to verify your identity. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed.

Right to Know. You have the right to know personal information we have collected about you, which includes:

• The categories of personal information we have collected about you, including:
  • The categories of sources from which the personal information was collected;
  • Our business or commercial purposes for collecting, selling, sharing, or disclosing personal information;
  • The categories of recipients to which we disclose personal information;
  • The categories of personal information that we sold, and for each category identified, the categories of third parties to which we sold that particular category of personal information;
  • The categories of personal information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of personal information.
• The specific pieces of personal information we have collected about you.

Right to Delete Your Personal Information. You have the right to request that we delete personal information we collected from you, subject to certain exceptions. Where we use deidentification to satisfy a deletion request, we commit to maintaining and using the information in deidentified form and will not to attempt to reidentify the information.

Right to Correct Inaccurate Information. If you believe that personal information we maintain about you is inaccurate, you have the right to request that we correct that information.

Right to Opt Out of Sales and Sharing of Personal Information. You have the right to opt out of the sale of your Personal Information, and to request that we do not share your Personal Information for cross-context behavioral advertising. To opt-out, please click here.

Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use or disclose sensitive personal information about California Applicants for purposes to which the right to limit use and disclosure applies under the CCPA.

Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us, including retaliation against you as a California Applicant.

Contact Us

If you have any questions related to your personal information under CCPA, please email us at privacy@vanguard.com.

Revised March 2024