CALIFORNIA RESIDENT PRIVACY NOTICE

Last Modified: 6.21.23

Electric Boat Corporation (“EB”) is committed to complying with the California Consumer Privacy Act (“CCPA”) effective January 1, 2020 and as amended by the California Privacy Rights Act (“CPRA”) effective January 1, 2023, and with all other data privacy laws in the jurisdictions in which it has employees. This California Resident Privacy Notice applies solely to employees, consultants and applicants for employment of EB and its managed affiliates, who reside in the State of California and from whom we collect “Personal Information” as described in the CCPA.

The CCPA and CPRA define “Personal information” as information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Under the CPRA, “Personal Information” further includes “Sensitive Personal Information” such as social security number, driver’s license number, state identification card, passport number, certain financial account data, genetic data, certain biometric data, precise geolocation, racial and ethnic origin, content of consumer communications (email, mail, or text), unless the business is the intended recipient, and information collected concerning a consumer’s health, sex life, or sexual orientation.

As part of recruitment and new employee onboarding processes, EB collects and processes personal information relating to job applicants and employees. EB is committed to being transparent about how it collects and uses that data and to meeting its data protection responsibilities.

INFORMATION WE COLLECT

EB collects a range of information about you. This includes:

• Identifiers and Personal Information: legal name, alias name, signature, current and past addresses; email address, telephone and cell phone numbers; Social Security number, driver’s license number or state identification card number; passport number, or other similar identifiers; date of birth, marital status, birth location, country of citizenship; education, licenses and certification history; employment history, medical information, names of relatives employed by the Company; military and government service information; names and contact information of references provided at the time of application; and invention disclosures (if any).
• Protected Class/Special Categories of Information: gender, race/ethnicity, disability status, and veteran status.
• Health Information: medical history, job restrictions and medical limits; substance abuse testing; workplace accident and illness information, health insurance information, and other information to determine reasonable accommodations during the post offer onboarding process and/or during your employment at EB.
• Criminal Background and Consumer Credit Report Information: personal identification information (see above), copies of identity documents, gap or travel activities, publicly sourced information (e.g. media or online information), driver’s license and status, including driver history and expiration date; opinions from references provided, civil court records, sanctions with professional bodies, criminal history; financial information such as credit history, bankruptcy, financial judgments or tax information; appearance on global sanctions or terrorist watch lists and/or restricted-denied party screening; driving records, penalties and restrictions.
• Emergency Contact Information: name and contact information and relationship to employee.
• Security Clearance Application Information (if applicable): employment history, residence, education, foreign travel, foreign associates, criminal history, civil litigation history, names of all persons residing in the same domicile, current and former neighbors of the clearance applicant, extended family member names, and history of drug use.
• Pay Information: pay rate/compensation, payroll deduction information, and banking information for direct deposit.

• Benefits Enrollment and Administration Information: benefit selection information; beneficiary information; leave of absence information; and other information necessary to administer benefits programs and process benefits claims

• Performance Management Information: employment status (full-time or part-time, regular or temporary); work schedule; job assignments; hours worked; business travel information; expatriate and secondment assignments; accomplishments and awards; training and development information; performance evaluation information; discipline and counselling information; and employment termination information.
  
  
• Electronic Communications Information: such as e-mail, computer, internet, telephone, and mobile device usage; IP address; log-in information; and location information.

Legal and Contractual Information: information necessary to respond to law enforcement and governmental agency requests, comply with legal and contractual obligations, exercise legal and contractual rights; and initiate or respond to legal claims.

EB will collect the above information through several means. For example, data might be contained in application forms; resumes; writings samples; obtained from your passport, driver’s license, or other identity document; collected through in person or telephonic interviews, during the new employee onboarding process, and/or during your employment at EB.

EB may also collect personal data about you from third parties, such as former employers or references supplied by former employers. In addition, EB conducts a standard background check of applicant(s) prior to extending a job offer.

Data will be stored in a range of different places, including on your digital and paper applicant record, in HR management systems (paper and digital) and other electronic or digital systems (including email).

Some category information listed above may overlap with other categories and may be collected during the application process and/or to onboard new employees prior to their start date to comply with applicable laws.

For purposes of this notice, Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

As described below, personal information about you is collected, processed and stored within the context of your role as an employee of EB and for uses related to your employment with EB.

WHY WE COLLECT PERSONAL DATA

EB needs to process data to take steps prior to entering into an employment relationship with you to manage its employment relationship with employees and to comply with applicable laws. In some cases, EB will need to process data to ensure that it is complying with its legal and contractual obligations, and to establish, exercise, and defend legal and contractual rights and claims. For example, it is mandatory to check an offeree’s eligibility to work in the U.S. before commencing employment and when the U.S. Navy requires EB to obtain security clearances for employees working on certain projects involving classified information.

EB collects emergency contact information from its employees in order to contact the designated emergency contact in the event of an emergency.

EB has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows EB to manage the recruitment process, evaluate and confirm an applicant’s qualification for employment and decide to whom to offer a job. EB may also need to process data from job applicants to report to regulators or defend against legal claims.

EB may process special categories of data, such as information about veteran, disability, race/ethnic origin and gender status to monitor recruitment statistics. EB may also collect information about whether or not applicants/employees are disabled to make reasonable accommodations for applicants and employees who have a disability. EB processes such information to carry out its obligations in relation to employment.

EB also collects electronic communication information to protect Company, customer, and employee property, equipment and confidential information; monitor employee performance; and enforce the Company’s electronic communications acceptable use Policies.

PURPOSES OF THE PERSONAL INFORMATION PROCESSING

Where it is necessary, we use your Personal Information to help ensure effective personnel administration, for the following purposes:

• Payroll, Benefits, and Insurance: Personal Information is used to administer the salaries, benefits, and insurance that you receive under your employment agreement, including annual merit increases, any other salary adjustments, annual bonus payments, and retirement benefits, including other benefits provided to retirees; income tax; and social security withholdings.
  
  
• Travel Arrangements and Business Expense Processing: Personal Information is used to make travel arrangements and to process business expenses associated with business travel; to process business expenses associated with approved coursework, books and periodicals, and training; to process business expenses associated with approved business expenditures.
  
  
• Performance Review and Management: EB uses Personal Information to facilitate personnel performance management and career development, notably through annual performance appraisals; annual salary reviews, and; if any, disciplinary sanctions in accordance with local legislation.
  
  
• Succession Planning and Leadership Development: Personal Information may be used for succession planning and leadership development of employees.
  
  
• Administration of Compensation Program or Employee Equity Plans: Personal Information may be used in the administration of compensation program or equity plans.
  
  
• Legal Obligations: EB may use your Personal Information to comply with our legal obligations, such as income tax and social security withholdings; disability; maternity obligations; or cooperation with courts, including civil actions, and with law enforcement agencies in legal investigations regarding suspected criminal activities or other suspected illegal activities. Subject to local law requirements, EB may use Your Personal Data to protect its legal rights or support any claim, defense or declaration in a case or before any jurisdictional and/or administrative authority or arbitration or mediation panel, in the context of disciplinary actions/investigations or of internal or external audit and inquiries.
  
  
• Security: Some of your Personal Information is collected and processed for security purposes including office access and IT Resources access, according to EB’s Information Technology & Security Policies. Personal Information may be collected in the course of IT Resources security procedures, including security penetration tests, for which IT experts will try to access our system to find any security breaches.
  
  
• General Management and Human Resources Administration: Personal Information may also be used for administration purposes, including employee feedback through the use of employee surveys and contacting employees; administration of email systems and company directories; assignment of offices and other company equipment; assignment of identification badges; and evaluations performed for purposes such as headcount, diversity and inclusion measures and overall corporate programs to promote an optimal workplace. Personal Information may also be used for the company’s planning and budgeting; financial reporting; corporate reorganizations; outsourcing; restructuring; and acquisitions and divestments. Personal Information may also be used for human resources administration such as to obtain feedback from personnel about the company and the work-life environment, so as to identify areas where the organization can improve and related matters.
  
  
• Reporting: Personal Information may be collected through the compliance hotline implemented by General Dynamics Corporation as a means of allowing employees to report allegations related to the following matters, or other areas of concern: accounting, internal accounting controls, auditing matters, bribery, banking and financial crime; facts affecting the vital interest of the company; or issues related to employees’ physical or moral integrity. The collected Personal Data may be transferred to General Dynamics Corporation located in Falls Church, Virginia USA in the event that the message received through the reporting system may affect substantially the legitimate interests of General Dynamics Corporation, EB or any of their affiliates.
  
  
• Performance in Your Job Within EB: To assign a workspace, office, computers, other EB equipment, to keep track of the individuals to whom the equipment is assigned, and to enable access to EB’s IT systems and applications, including third party applications used to perform your job.

WHO CAN ACCESS THE DATA

Your information may be shared internally for the purposes of the recruitment and onboarding process. This includes members of the Human Resources, Employment, Medical, Information Technology, Finance, Accounting, Payroll, Contracts, Procurement, Ethics, Business Services, Security, Tax, and interviewers involved in the recruitment process; Vice Presidents, directors, managers and supervisors in the business area with a vacancy where access to the data is necessary to administer designated responsibilities.

EB may share your data with former employers for the purpose of obtaining references for you, and a third-party background check provider to obtain necessary background checks prior to extending an offer of employment.

We may disclose the Personal Information described above with service providers that assist us in providing the services and goods described in this policy.  These service providers include payroll processing providers, background check providers, benefits administrators, health insurance providers, travel providers and credit card issuers. 

We do not sell or share personal information as defined in the CCPA or CPRA. 

HOW WE PROTECT YOUR DATA

EB takes the security of your data seriously. EB has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by specific employees based upon their roles and in the proper performance of their duties.

HOW LONG DO WE KEEP DATA

EB will only keep your data for so long as they are relevant for the purposes for which they were collected or as required by law.

YOUR RIGHTS AND RESPONSIBILITIES

The CPRA provides California residents with specific rights regarding their personal information. This includes the right to access and obtain a copy of your data on request, require EB to change incorrect or incomplete data, require EB to delete or stop processing your data, and object to the processing of your data where EB is relying on its legitimate interests as the legal ground for processing.

You may contact EB at DataPrivacy@gdeb.com if you would like to exercise any of these rights or believe that EB has not complied with your data protection rights.

You are responsible for providing a copy of this Privacy Notice to your emergency contacts and beneficiaries prior to disclosing their personal information.

IF YOU DO NOT PROVIDE PERSONAL DATA

You are under no statutory or contractual obligation to provide data to EB during the recruitment process. However, if you do not provide the information, EB may not be able to process your application properly or at all. In such cases, you will not be eligible for employment with EB.

CHANGES TO THIS NOTICE

EB may change or update portions of this privacy notice at any time without prior notice to you. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting our website and this Privacy Notice to check for any changes.

CONTACT INFORMATION

If you have questions regarding this Privacy Notice, you may contact EB at dataprivacy@gdeb.com or by phone at 860-433-8279.