Contract Worker and Non-Employee Worker Data Privacy Notice

This Notice applies to individual contractors, contract workers, and other non-employees who perform work for Verizon (for purposes of this notice, “Workers”). 

International, national and state laws and regulations place various restrictions on the processing and movement of personal data. This Notice tells you how Verizon will use personal data about you relating to your engagement at Verizon and explains your privacy rights. Where there is a conflict between this Notice and any local laws applicable to your work with Verizon, the latter prevails. 

When we refer to “Verizon” in this document we mean both the Verizon company which you are assigned to and the wider Verizon group of companies. The Verizon company to which you are assigned determines what personal data (also referred to as “Worker Data”) is needed and how it should be used.  Some countries use the term “data controller”, “principal” or “data fiduciary” to describe this role.

Verizon may be required by law to collect certain personal data about you. Failure to provide this information may prevent or delay the fulfillment of our obligations. 

If you have any questions, about any aspect of this notice, or how Verizon handles personal data, or if you would like an alternative format of this notice because of a disability, you can contact the Privacy Office at:

If you are based in the US: privacyoffice@verizon.com

If you are based outside the US: International-Data-Privacy@verizon.com  

Below are answers to key questions you might have about how Verizon will use personal data about you during your engagement.

We collect information from you which might include:

• Identifiers, for example, your name, home address and contact details, signature, date of birth, driver’s license, passport, state or national identity number or similar identity number, and photographs of you. 
• Professional Information, for example, employment history, educational background, engagement history with Verizon, and areas of expertise
• Administrative information, for example, details of your next of kin or emergency contact details. 
• Commercial Information, such as the details of the contract under which you work.
• Payment information, for example, hours worked.
• Health information, including, for example, information about an on-the-job injury.
• Biometric information, for example a fingerprint or facial recognition for access control to Verizon sites.
• Geolocation data, for example, GPS tracking on company vehicles or devices
• Login credentials, for example, login credentials to an online account owned or subscribed to by the Company. 

Personal data that we obtain about you from other sources will vary depending on what is permitted or required by the laws which apply to your location.  Subject to those laws the personal data which Verizon collects from other sources might include:

• Placement information: Personal data about you which your employer or another company at your request has provided to us for the purposes of setting up your engagement.
• Usage of Verizon Electronic Resources: As explained in the Supplier Code of Conduct, Verizon may monitor your use of Verizon-issued devices, equipment, and network. This may include collecting the IP address and other unique identifiers of your Verizon-issued computer, tablet, smartphone and other devices.
• Sensory or Surveillance Data, for example: voice-mails, recordings of meetings or video-conferences, and footage from video surveillance cameras.
• Background check information from background screening agencies or publicly available registers. 
• Publicly available professional profiles on websites or social media (e.g. LinkedIn).
• Reference information, such as information about your performance or conduct from employees or other Workers, customers, or suppliers you work with who may provide feedback about you.

Verizon needs to process personal data in order to:

• carry out workforce administration including engaging you, determining whether you have satisfied your contractual obligations, administering payments, tracking absences, reporting, management, and orientation 
• respond to your enquiries and requests;
• fulfill our legal obligations, including our legal obligations to you such as health and safety obligations;
• detect, investigate and/or prevent issues or complaints, including conducting internal audits and investigations;
• improve efficiency and productivity using data analytics to assess how staff use Verizon systems, applications, and other tools; 
• provide for travel arrangements and attendance at events;
• comply with various reporting or disclosure obligations under applicable laws and regulations (for example in relation to health and safety records); 
• manage the safety and security of our systems, network, people, assets, equipment, and buildings;
• provide you with alerts in the event of an emergency;
• conduct the business of Verizon, manage customer and supplier relationships and secure Verizon’s customers’ networks, operations, staff, assets and premises.
• manage and operate information technology and communications systems, risk management and insurance functions, budgeting, financial management and reporting, and strategic planning;
• manage litigation involving Verizon, and other legal disputes and inquiries; 
• in connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of Company or any of its subsidiaries or affiliates; and
• manage licenses, permits, and authorizations applicable to Verizon’s business operations.

In the majority of cases, the legal basis for our collection and use of personal data is one or more of the following: 

• to fulfill our contractual obligations to you and to exercise Verizon’s rights (for example relating to the Supplier Code of Conduct) in connection with your engagement with Verizon; 
• to comply with our legal obligations, for example complying with health and safety regulations and keeping a record of accidents in the workplace;
• to meet our legitimate interests, for example to manage our workforce effectively and to protect Verizon against criminal acts including theft and other risks. When we process personal data about you to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to balance Verizon’s needs with your interests or fundamental rights and freedoms; 
• your prior express and informed consent;
• in jurisdictions which do not include legitimate interests as a lawful basis, your consent to process personal data about you; 
• where Verizon is required to provide personal data to a public or administrative agency by law or court order;
• to protect your or another person's vital interests, for example by providing health information Verizon may hold about you to a doctor in a medical emergency.

In countries where a company is required to obtain consent to collect certain elements of personal data from its staff, your receipt of this Notice and your ongoing work with Verizon is deemed, where permitted by law and unless you raise an objection, to signify such consent. Where such deemed consent is not permitted by law, Verizon will request your express consent. 

Verizon will keep personal data during and after your assignment for as long as is necessary to achieve the purposes for which it was collected or as otherwise required by law or for lawful purposes, for example to resolve disputes and enforce our agreements. Verizon’s detailed Records Retention Statement with its Retention Schedule is available on VZWeb and provides more information about our record retention policy. 

Verizon retains the right to conduct monitoring activities in relation to your use of electronic communications (such as email and instant messaging), as set out in the company’s electronic communications and information security policies, both during and after your assignment. As electronic communications are considered to be company property Verizon may access electronic communications at any time without prior notice in accordance with applicable laws, including after your assignment ends. To the extent you use Verizon email and communication tools for personal use as permitted by the Supplier Code of Conduct, you may therefore wish to delete any private personal correspondence and information from such electronic communication methods prior to the end of your assignment.

• Verizon is a global enterprise comprised of a group of companies operating internationally which is headquartered in the United States. The Verizon company to which you are assigned will disclose personal data about you to other Verizon companies and their staff in other countries if it is necessary for the purposes explained in this Notice. These Verizon companies are bound, as required by law, to ensure that personal data is adequately protected as explained in Section 8 “How is personal data protected?”.
• Verizon may also need to make some personal data available to a law enforcement agency, court, regulator, government authority, auditors or other third parties. We may disclose personal data to these parties where this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
• Verizon may also disclose your business contact information to Verizon’s customers, suppliers, consultants, partners or other third parties when that information is necessary for business purposes. 
• Verizon uses suppliers to provide some services, for example to provide IT support, for travel and conference services, for cloud storage or to help maintain the security of our premises and systems. In these instances, Verizon discloses personal data of its staff to these suppliers so that they can provide the service. We ensure that the suppliers commit to protect the personal data (see Section 8 “How is personal data protected?”). 
• We may disclose personal data to any third party that purchases, or to which we transfer, all or substantially all of the assets and business of the Verizon company that you are assigned to. Should such a sale or transfer occur, we will use reasonable efforts to ensure that the entity to which we transfer personal data about you uses it in a manner that is consistent with this Notice.
• A list of the third parties, or categories of third parties, who process personal data of Verizon’s workforce can be obtained on request from the Privacy Office. 

• Verizon processes and stores personal data in access-controlled, centralized databases in the United States and India, your home country or elsewhere and in paper and electronic files located in the country or region where you are working. The electronic databases are controlled by specially authorized administrative Verizon staff only who may be located outside your home country. 
• Verizon places certain information, such as names, pictures, and business contact numbers in internal Verizon directories, and this information is accessible by all staff of Verizon. 
• Third party recipients of personal data may be located in the United States or in other countries. Some of these countries may not provide equivalent statutory protections for personal data as in your home country. In addition, personal data may be accessible by the courts, law enforcement and national security authorities in the countries where it is located. In these circumstances personal data is protected as required by law as outlined in Section 8 below “How is my personal data protected?”
• Certain personal data, such as your name and office location, will be included as standard in electronic communications which you make and receive on Verizon’s systems and equipment, and will be processed and stored by Verizon in accordance with the terms of this notice, Corporate Policy Instructions and the Verizon Code of Conduct. 

Verizon is committed to maintaining the security of personal data and has comprehensive corporate policies regarding information security. Verizon will protect personal data, wherever it is stored and when it is transferred to other Verizon companies or to third parties. 

When personal data is transferred:

• between Verizon companies, it is protected by our global corporate policies which include privacy and security policies and, where applicable, by intra-group agreements or Binding Corporate Rules (BCRs).
• to a supplier or service provider, we will ensure that they commit to protect personal data through appropriate terms and conditions in the contract.
• to a company in the context of a business acquisition or disposal, we will ensure that protection of the personal data is a condition of the contract.

In addition to information about you, you may also provide Verizon with information about your dependents, relatives and next-of-kin/emergency contacts for use in case of an emergency. You must tell those people that you have provided their data to Verizon and that Verizon stores and uses their data for the purposes for which you provided it in the manner set out in this Notice. You may wish to share this Notice with them.

In certain countries there may be data protection laws that may provide you with the following rights:

• the right to update and correct the personal data which Verizon holds about you. We encourage you to keep all your personal information up to date in the relevant workforce management platform. Please speak to your Verizon hiring manager for further information and assistance.
• the right to object to the processing of personal data about you by Verizon, or request that the processing by Verizon be restricted or that the personal data about you is deleted. This right applies in certain limited circumstances, which the Privacy Office will be able to explain to you.
• the right to request access to the personal data held about you by Verizon. You can do this by contacting the Privacy Office, or if you are a CA resident, complete the form in Section 11 or call the toll-free number.
• if we are required to seek your consent to process certain elements of personal data, you may withdraw your consent at any time.
• if you have a formal complaint or objection regarding the processing of personal data about you by Verizon, you may contact and lodge a complaint with the supervisory data protection authority in your home country where that option is available, but please contact the Verizon Privacy Office first for guidance and support. 
   

If you are a California resident, in addition to the points described above in Section 10, to the extent applicable, please note the following:

• You have the right to submit a verifiable request for copies of specific pieces of personal data about you (“right to know”) collected since January 1, 2022 and for information about Verizon’s collection, use, and disclosure of personal data about you during that same time period. 
• Verizon does not sell the personal data about Workers nor disclose personal data for cross-context behavioral advertising. 
• Verizon does not collect or process sensitive personal data or characteristics of protected classifications for the purpose of inferring characteristics about Workers.
• Verizon will not unlawfully discriminate or retaliate against you for exercising your rights under the California Consumer Privacy Act, as amended.
• You can exercise your rights by calling: 1-888-892-0053 or completing this form.  
• Verizon may also require additional steps to verify your requests. We will match data points that you provide against information about you that we already have in our records. We may require you to sign a declaration under penalty of perjury that you are the individual who is the subject of the request.
• If an authorized agent submits a request to know, correct, or delete on your behalf, the authorized agent must submit with the request either (a) a power of attorney that is valid under California law, or (b) document signed by you that authorizes the authorized agent to submit the request on your behalf.  In addition, we may ask you to follow the applicable process described above for verifying your identity.  You can obtain an “Authorized Agent Designation” form by contacting us at 1-888-892-0053.

Verizon may make changes to this Notice or replace it at any time. You will also be able to view the current Notice on Verizon's International Privacy Centre.

December, 2022