CANADIAN LINEN WORKFORCE PRIVACY NOTICE - CANADA

Effective date: January 1, 2020

Updated September 26, 2022; August 3, 2022; October 2, 2023

This notice (Notice) sets out how Canadian Linen collects, uses, stores and shares personal information about our staff, including our current and former employees, temporary staff and interns (employees), and our consultants, contingent workers, and independent contractors (contractors) (collectively, staff or you or your). This Notice also applies to applicants for employment with ,Canadian Linen (applicants).

For purposes of this Notice, Canadian Linen refers collectively to the Canadian Linen group company that employs or engages you or any of its affiliate entities (“Canadian Linen” or “we” or “our”). These companies can be reached using the relevant contact details set out in the “Your contact for any queries” Section below.

1 Information we collect about you

For purposes of this Notice, personal information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer. Personal information excludes deidentified information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular consumer. We will collect and use some or all of the following personal information before, during, and after your employment (or similar engagement):

Identifiers, such as name, date and place of birth, email, social insurance number (employees only), drivers’ license number (employees only), current and prior postal addresses, phone numbers;
Professional or employment information (employees and applicants only), such as department, work location, job title information, absences from work, performance information, criminal history, performance evaluations, job referral information, union membership (if applicable), and dependents’ information;
Internet or electronic network activity information, such as details of your use of and communications sent through Canadian Linen systems and geolocation information (if applicable). For example, Canadian Linen monitors website browser activity on company devices to ensure staff are not accessing websites that may present harm to the user or company;Other information you may provide when you communicate with us or participate in our surveys or promotions
Commercial information (employees only), such as details of travel that you undertake, or expenses you incur, in connection with your employment or engagement;
Protected classifications (employees only), such as your race, ancestry, gender, age, marital status, family status, medical information, and disability status;
Education information (employees and applicants only), such as your prior training; degrees, certifications;
Financial information (employees only), such as your bank account information or credit history if applicable;
Driving history (employees and applicants), drug and alcohol testing (employees, and only in rare circumstances);
Vehicle usage information (drivers only), collected through (i) outward facing dashboard cameras, or (ii) telematics devices which may be installed in company vehicles. Such devices may record data such as seatbelt usage, idling time, speeding, aggressive driving (harsh acceleration, braking and/or cornering), location data, trip history, and backing up. This is further described in the Telematics Policy – Canadian Operations;
Video monitoring (in-person staff), collected through 24/7 surveillance cameras positioned at Canadian Linen properties. These cameras are primarily external facing, and used for security purposes. Although not a primary purpose (absent a specific investigation), if employee misconduct is captured by surveillance cameras, footage may be used for disciplinary purposes;
Monitoring information, including activities performed at work, timestamps, and efficiency scores, as collected through various programs and company devices, described further at the electronic monitoring section below.
Information collected through IT sessions. If you request or require IT assistance, our IT staff may conduct a remote IT takeover, during which they may be able to see device activity including keystrokes made during the session. Staff are encouraged to limit the personal information stored on company devices or visible on the desktop or device home-screen to limit any personal information inadvertently displayed during an IT session.
Other information provided by you, including internal survey responses, or other information collected in the course of an investigation.

2 How we use personal information

The purposes for which we use your personal information are as follows:

Recruiting and Hiring (applicants and employees only), such as determining your eligibility for work, checking references, and performing background checks.
1. Recruiting and Hiring (applicants and employees only), such as determining your eligibility for work, checking references, and performing background checks.
Conducting checks (applicants and employees), such as background checks, including criminal background checks, vulnerable sector screening verification, credit checks, anti-fraud checks, checks to prevent fraud and money laundering, and drug / alcohol tests, to the extent allowed under applicable employment laws.
1. For purposes of conducting checks, we process your identifiers, protected classifications, credit history, professional or employment information, education history, driving history and drug / alcohol testing.
General HR administration (employees only), such as staff communications, on-boarding and off-boarding, succession planning, managing your career development, assessing your suitability for a particular role, assessing your salary and other compensation, and performance.
1. For our general HR administration, we process your identifiers, professional or employment related information, monitoring information, education information and financial information.
Administering salary, expenses, and staff benefits (employees only), including administering insurance, payroll, retirement plans, and other employee benefits and tax, and in order to administer corporate expenses and reimbursements (including viewing details of transactions made using corporate credit cards and corporate travel undertaken)
1. To administer salary, expenses, and benefits, we process your identifiers, professional or employment information, commercial information, and financial information.
Managing absences and occupational health requirements (employees only). including to keep a record of absences and to contact dependents or other family members in the event of an emergency.
1. To manage absences and occupational health requirements, we process your identifiers, professional or employment information and protected classifications.
Electronic Monitoring (employees). Canadian Linen monitors activities on company devices and systems for employee management purposes, including to monitor and manage compliance with Canadian Linen policies, assess workplace productivity, and prevent, detect and fight fraud or other illegal or unauthorized activities including but not limited to activities considered unacceptable as documented in Business Conduct Policy and Acceptable Use Policy
1. For monitoring and security purposes, we process your identifiers, internet or electronic network activity information, monitoring information, and employment or professional information.
2. Such monitoring may include any use of Canadian Linen assets or resources, including but not limited to the use of a computer, telephone, or other communications equipment including corporate issued cellular/mobile devices, at any and all times. In addition to the above, Canadian Linen makes use of the following employee management software:
1. Spindle, which collects certain information (work task, timing, and efficiency) when employees scan into stations using their Spindle cards;
2. Kronos, which tracks the start and stop times, and work hours of non-salaried employees (as submitted by employees); and
3. ManagerPlus, which tracks maintenance team activities as submitted by maintenance team members. This information is used primarily for maintenance and repair purposes, but may be used for investigation and employee management purposes in certain situations.
Fleet Vehicle Monitoring (Drivers only). Where fleet vehicles are provided, vehicle usage information may be collected, using telematics devices installed in the vehicle, and/or dashboard camera footage. This information is collected for purposes including, to defend you and/or Canadian Linen against legal action, to investigate incidents, to monitor and encourage the safe operation of Canadian Linen vehicles, to monitor, track and protect Canadian Linen’s inventory of vehicles, and to monitor and manage compliance with Canadian Linen’s policies.
Information Technology (IT) purposes, such as providing IT support for Canadian Linen Information Systems and user authentication.
1. To administer salary, expenses, and benefits, we process your identifiers, professional or employment information, commercial information, and financial information.
Storing staff communications, records and work product, including as required in order to operate the Canadian Linen business. These communications and records may contain personal information both related to work and private matters.
1. For storing staff communications, records, and work product, we process your identifiers, professional or employment information, and internet electronic activity information.
Complying with our legal obligations, like monitoring equal opportunities, complying with audits, or where necessary, for exercising, establishing, or defending legal claims, including the disclosure of your personal information to third parties in connection with proceedings or investigations anywhere in the world, such as public authorities, law enforcement agencies, regulators and third party litigants.
1. For these purposes, we collect your identifiers, protected classifications (employees only), employment and professional information, and internet or electronic network information.
When changing our business structure, such as in the event of a business sale or corporate restructuring, where we may disclose your personal information to any potential acquirer of, or investor in, any part of the Canadian Linen business (and to their legal advisors and consultants) for the purpose of that acquisition or investment.
1. For this purpose, we process your identifiers, employment or professional information, and protected classifications.

3 How we share personal information

In connection with the purposes listed above in section 2 and consistent with this Notice:

The Canadian Linen group company that employs or engages you shares your personal information with Canadian Linen affiliates where required for Canadian Linen’s internal administrative purposes. In particular, your personal information may be shared with Canadian Linen affiliates outside Canada, which will collect, use and store your personal information in the United States. Such affiliates are authorized to process your personal information on behalf of your employer, in order to assist with human resources tasks including administering employee salaries as well as compensation, equity and/or benefit plans. Canadian Linen may grant other group entities access to such data where required for the purposes consistent with this Notice.
In limited situations, Canadian Linen may share your personal information with certain third parties for the purpose of managing Canadian Linen’s relationship with its clients and related parties, such as unions.
Subject to local legal requirements, we may use third parties to assist us with human resources and IT related services, such as payroll providers, healthcare providers, insurers, retirement administrators, information systems storage providers, IT managed service providers, accountants and legal advisors, vehicle telematics platform providers, and other third party vendors that need your personal information to provide their services. We require that such external service providers or third parties will ensure adequate protection for your personal information and will comply with local legal requirements and our privacy and data security standards.
In addition, we may share your personal information with other third parties where disclosure is permitted or required by law to comply with legal obligations, protect our rights and property, or protect the safety of our staff or any third party. For example, for employees that drive our company vehicles, we share employee driver’s license number, name and province with the Ministry of Transportation in order to comply with regulatory requirements.

4 Transfer of information across borders

The service providers and affiliates mentioned above may be located outside of Canada. Accordingly, your personal information may be transferred outside of Canada and may be accessible to courts, law enforcement and national security entities in such foreign jurisdictions. Similarly, if you are located in Quebec, your personal information may be communicated outside of Quebec. If you have any questions, or wish to obtain further written information about our policies and practices with respect to the processing of personal information by our service providers or affiliates outside of Canada, please contact the Canadian Linen Privacy Team at privacy@vestis.com..

5 Storage of personal information

We will retain your personal information for as long as is necessary for the purposes for which it was collected and any other permitted or required purposes (such as to comply with regulatory requirements to retain such information). Our retention periods are based on business needs and relevant laws. Please note that these periods may be extended where reasonably necessary (for example where we are required to do so by law or by a regulator). We will either deidentify or securely destroy personal information that we no longer need. We reserve the right to use deidentified information for any legitimate business purpose without further notice to you or your consent.

6 Your rights

Depending on where you are located, you may have certain data protection rights provided by privacy laws. These may include:

Access and/or Correction. You may access and/or correct or update your personal information by contacting privacy@vestis.com..
Withdrawing Consent. Where consent is relied upon as the basis for collecting your personal information, you may withdraw consent to the continued use or disclosure of your personal information (subject to legal and contractual restrictions and reasonable notice). You may withdraw consent by contacting privacy@vestis.com..
Please refer to privacy laws in your particular geographic location for specific rights that may be provided in addition to the general description above.

7 Your contact for any queries

If you have any queries or concerns regarding personal information, please contact the Privacy Team at privacy@vestis.com..

8 Changes to this Notice

This Notice was last updated on the effective date listed at the top of this Notice. We will notify you of any material changes to this Notice by posting information about the change on the Intranet or by other reasonable means, prior to the change taking effect. We will retain previous versions of this policy for at least three years.