PERSONAL INFORMATION CATEGORY

RETENTION PERIOD

BUSINESS PURPOSE

Identifiers, such as your full name, contact information, gender, date of birth, signature, Social Security number, driver’s license or state identification numbers, and similar information for your dependents and beneficiaries.

Termination + 4 years

• Recruit and process employment applications, including verifying eligibility for employment and conducting background and related checks, e.g., Motor Vehicle Record Checks.
• Conduct employee onboarding
• Maintain and administer payroll and employee benefit plans, including enrollment and claims handling
• Maintain personnel records and complying with record retention requirements
• Provide employees with human resources management services and employee data maintenance and support services
• Communicate with employees and their emergency contacts and plan beneficiaries
• Comply with applicable state and federal labor, employment, tax benefits, workers’ compensation, disability, equal employment opportunity, workplace safety and related laws.
• Prevent unauthorized access to or use of New Belgium property, including information systems, electronic devices, network, and data
• Ensure employee productivity and adherence to New Belgium’s Code of Conduct and policies and procedures
• Conduct internal audits and investigate complaints, grievances, and suspected violations of New Belgium’s Code of Conduct and policies and procedures
• Response to government requests and as required by applicable law or court order
• Exercise or defend the legal rights of New Belgium and its employees, affiliates, customers, contractors, and agents

California Customer Records employment and personal information, such as your name, signature, Social Security number, physical characteristics or description, photograph, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, current employment, employment history, membership in professional organizations, licenses and certification, bank account number, credit card  number, debit card number, or any other financial, medical, or health insurance information.

Termination + 4 years

Same purposes as for the Identifiers category above.

Protected classification characteristics under California or federal law, such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital tatus, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, reproductive health decision making, military and veteran status, or genetic information (including familial genetic information)

Termination + 4 years

• Comply with federal and state equal employment opportunity laws
• Design, implement and promote New Belgium’s Diversity, Equity and Inclusion programs
• Perform workforce analytics, data analytics, and benchmarking
• Conduct internal audits, grievances, and suspected violations of New Belgium’s Code of Conduct and policies and procedures
• Exercise or defend the legal rights of New Belgium and its employees, affiliates, customers, contractors, and agents

Biometric information, such as fingerprints, keystroke or other physical patterns and certain Wellness metrics

Termination + 4 years

• Fingerprinting for a criminal background check after an initial offer of employment is made (depending on position).  Criminal background checks protect New Belgium, mitigate risk, and avoid potential negligent hiring lawsuits
• Administer and design health wellness programs
• Exercise or defend the legal rights of New Belgium and its employees, affiliates, customers, contractors, and agents

Internet or other similar network activity information, including all activity on the Company's information systems (such as internet browsing history, search history, intranet activity, email communications, social media postings, stored documents and emails, usernames, and passwords) and all activity on communications systems (such as phone calls, call logs, voicemails, text messages, chat logs, app use, mobile browsing and search history, mobile email communications, and other information regarding an employee's use of company-issued devices).

Termination + 4 years

• Facilitate the efficient and secure use of New Belgium information systems
• Ensure compliance with New Belgium information systems policies and procedures.
• Comply with applicable state and federal laws
• Prevent unauthorized access to, use, or disclosure or removal of New Belgium's property, records, data, and information
• Enhance employee productivity
• Conduct internal audits and investigate complaints, grievances, and suspected violations of New Belgium’s Code of Conduct and policies and procedures
• Exercise or defend the legal rights of New Belgium and its employees, affiliates, customers, contractors, and agents

Geolocation data, such as the time and physical location related to use of an internet website, application or device, and CPS location data from mobile devices of employees who participate in New Belgium’s Company Vehicle program

Termination + 4 years

• Improve safety of employees, customers, and public regarding use of New Belgium property and equipment
• Prevent unauthorized access, use, or loss of New Belgium property
• Improve efficiency, logistics, and supply chain management
• Ensure employee productivity and adherence to New Belgium’s Code of Conduct and policies and procedures
• Conduct internal audits and investigate complaints, grievances, and suspected violation of New Belgium’s Code of Conduct and policies and procedures

Sensory and surveillance data, such as COVID-19 related temperature checks and call monitoring and video surveillance

Termination + 4 years

• Comply with applicable state and federal laws, including on workplace health and safety
• Prevent unauthorized access, use, or loss of New Belgium property
• Improve customer service
• Exercise or defend the legal rights of New Belgium and its employees, affiliates, customers, contractors, and agents

Professional or employment-related information, such as employment application information (work history, academic and professional qualifications, educational records, references, and interview notes, background check, drug testing results, work authorization, performance and disciplinary records, salary, bonus, commission, and other similar compensation data, benefit plan enrollment, participation, and claims information, leave of absence information including religious, military and family obligations, health data concerning employee and their family members.

Termination + 4 years

• Recruit and process employment applications, including verifying eligibility for employment, background checks, and onboarding
• Design and administer employee benefit plans and programs, including for leaves of absence
• Maintain personnel records and comply with record retention requirements
• Communicate with employees and their emergency contacts and plan beneficiaries
• Comply with applicable state and federal labor, employment, tax, benefits, workers' compensation, disability, equal employment opportunity, workplace safety, and related laws
• Prevent unauthorized access to or use of New Belgium's property, including its information systems, electronic devices, network, and data
• Ensure employee productivity and adherence to New Belgium’s Code of Conduct and policies and procedures
• Conduct internal audits and investigate complaints, grievances, and suspected violations of New Belgium’s Code of Conduct and policies and procedures
• Evaluate and provide useful feedback about job performance, facilitate better working relationships, and for employee professional development 
• Exercise or defend the legal rights of New Belgium and its employees, affiliates, customers, contractors, and agents

Non-public education information, such as education records, degrees and vocational certifications obtained, report cards, and transcripts

Termination + 4 years

• Evaluate an individual’s appropriateness for hire, or promotion or transfer to a new position at New Belgium

Inference drawn from other personal information to create a profile or summary, for example an individual’s preference, abilities, aptitudes, and characteristics.

Termination + 4 years

• Engage in human capital analytics, including to identify correlations about individuals and job success, analyze data to improve retention and productivity, and analyze employee preferences to inform human resources policies and procedures
• Conduct applicant reference checks to assist in hiring decisions 

SENSITIVE PERSONAL INFORMATION CATEGORY

RETENTION PERIOD

BUSINESS PURPOSE

Government identifiers, such as your Social Security number, driver's license, state identification card, and passport and visa information, and immigration status and documentation.

Termination + 4 years

• Recruit and process employment applications, including verify eligibility for employment and conducting background and related checks
• Process and administer payroll and employee benefit plans, including enrollment and claims handling
• Maintain personnel records and comply with record retention requirements
• Provide employees with human resources management services and employee data maintenance and support services
• Communicate with employees and their emergency contacts and plan beneficiaries
• Comply with applicable state and federal labor, employment, tax benefits, workers' compensation, disability, equal employment opportunity, workplace safety, and related laws
• Prevent unauthorized access to or use of New Belgium property, including information systems, electronic devices, network, and data
• Respond to law enforcement requests and as required by applicable law or court order

Complete account access credentials, such as user names, account numbers, or card numbers combined with required access/security code or password. 

Termination + 4 years

• Recruit and process employment applications, including verify eligibility for employment and conducting background and related checks
• Provide employees with human resources management services and employee data maintenance and support services
• Prevent unauthorized access to or use of New Belgium information systems, electronic devices, network, and data 

Precise geolocation, such as physical access to a Company office location, or the location of a delivery, sales, or other employee in the field. 

Termination + 4 years

• Improve safety of employees, customers, and the public regarding use of New Belgium property and equipment
• Prevent unauthorized access, use, or loss of New Belgium property
• Improve efficiency, logistics, and supply chain management
• Ensure employee productivity and adherence to New Belgium’s Code of Conduct and policies and procedures.
• Conduct internal audits and investigate complaints, grievances, and suspected violations of New Belgium’s Code of Conduct and policies and procedures
• Exercise or defend the legal rights of New Belgium and its employees, affiliates, customers, contractors, and agents

Racial or ethnic origin

Termination + 4 years

• Comply with federal and state equal employment opportunity laws
• Design, implement, and promote New Belgium’s diversity, equity and inclusion programs
• Perform workforce analytics, data analytics, and benchmarking
• Conduct internal audits and investigate complaints, grievances, and suspected violations of New Belgium’s Code of Conduct and policies and procedures

Religious or philosophical beliefs

Termination + 4 years

• Review and process religious reasonable accommodation requests
• Exercise or defend the legal rights of New Belgium and its employees, affiliates, customers, contractors, and agents 

Mail, email, or text messages contents not directed to New Belgium

Termination + 4 years

• Conduct internal audits and investigate complaints, grievances, and suspected violations of New Belgium’s Code of Conduct and policies and procedures
• Exercise or defend the legal rights of New Belgium and its employees, affiliates, customers, contractors, and agents

Genetic Data

Termination + 4 years

• Investigate and process workers' compensation claims
• Process health insurance claims

Unique identifying biometric information

Termination + 4 years

• Fingerprinting for a criminal background check after an initial offer of employment is made. Criminal background checks protect New Belgium, mitigate risk, and avoid potential negligent hiring lawsuits.
• Ensure accurate time records
• Exercise or defend the legal rights of New Belgium and its employees, affiliates, customers, contractors, and agents

Health information, including job restrictions and workplace illness and injury information

Termination + 4 years

• Investigate and process workers' compensation claims
• Process health insurance claims
• Ensure equal access to retirement programs and fertility planning by same-sex spouses
• Ensure equal family leave policies and insurance for transgender surgeries

Sex life or sexual orientation information

Termination + 4 years

• Investigate and process workers' compensation claims
• Process health insurance claims
• Ensure equal access to retirement programs and fertility planning by same-sex spouses
• Ensure equal family leave policies and insurance for transgender surgeries