NORTHWEST HARDWOODS APPLICANT PRIVACY POLICY  


1. Introduction and Scope 

Northwest Hardwoods, Inc. ("NWH" or the "Company") respects the privacy of individuals applying for employment and is committed to protecting personal information collected during the recruiting and hiring process. This Applicant Privacy Policy (this "Policy") describes the types of information the Company may collect, how such information may be used, disclosed, retained, and safeguarded, and the rights applicants may have under applicable law. 


This Policy applies to all applicants for employment with NWH, regardless of the method of application or the state or jurisdiction in which a position is located. 


By submitting an application for employment or creating an applicant account through the Company's recruiting platform, applicants acknowledge that they have read and understood this Policy. The Company's collection and use of applicant personal information is grounded in its legitimate business interests in evaluating candidates and complying with applicable legal obligations. 


This Policy does not constitute a contract of employment or create any contractual or legal obligation on the part of the Company. Employment with NWH is at-will unless otherwise expressly agreed in writing. 


2. Information We Collect 

The Company may collect personal information including, but not limited to: 

  • Contact information: name, address, telephone number, and email address 
  • Application materials: resume, cover letter, employment history, education history, professional qualifications, certifications, and references 
  • Voluntary equal employment opportunity (EEO) information, including race, ethnicity, gender, disability status, and veteran status, where collected pursuant to applicable law 
  • Interview and assessment records 
  • Background screening information, where permitted by law and subject to separate disclosure 
  • Drug testing results, where required for applicable positions and permitted by law 
  • Internet or electronic activity data related to use of the Company's recruiting platform (e.g., login activity, application status interactions) 

Applicant information may be collected directly from the applicant, through the Company's recruiting systems, from references, from prior employers where authorized, and from authorized third-party service providers involved in the recruiting or onboarding process.

 

Applicants selected for employment may be required to provide additional information during the onboarding process, including information necessary for payroll administration, benefits enrollment, tax reporting, employment eligibility verification, background screening, and compliance with applicable law. Such information is governed by the Company's Employee Privacy Policy provided at the time of onboarding. 


By providing your mobile phone number, you consent to receive text messages (SMS/RCS) from Northwest Hardwoods regarding your application status, interview scheduling, and employment opportunities. Message and data rates may apply. You may opt out of receiving text messages at any time by replying "STOP" to any message you receive from us. 


3. How We Use Applicant Information 

The Company uses applicant information for the following legitimate business purposes: 

  • Evaluating qualifications and suitability for employment 
  • Communicating with applicants regarding employment opportunities and application status 
  • Scheduling and conducting interviews 
  • Conducting background checks and reference checks where permitted by applicable law 
  • Administering pre-employment drug testing for applicable positions, where permitted by applicable state and local law 
  • Complying with federal, state, and local legal obligations 
  • Improving and administering the Company's recruiting processes 
  • Considering applicants for future employment opportunities 

The Company does not use applicant information for automated decision-making that produces legal or similarly significant effects on applicants without human review, except as otherwise disclosed. To the extent the Company uses artificial intelligence or algorithmic tools to assist in resume screening or candidate ranking, applicants will be informed by separate disclosure where required by applicable law, including but not limited to the laws of Illinois, Maryland, and New York City. 


4. Background Screening and Drug Testing 

For certain positions, Northwest Hardwoods may conduct background screenings through its third-party background screening provider, First Advantage, in accordance with applicable federal, state, and local laws, including the Fair Credit Reporting Act ("FCRA"). Applicants will receive separate disclosures and written authorization forms where required by law prior to any background check being initiated. 


For positions requiring pre-employment drug testing, applicants will be notified at the time of conditional offer. Drug testing is administered through authorized third-party providers. Results are used solely to evaluate fitness for the applicable position and are handled with restricted access as described in Section 6. NWH complies with all applicable state and local laws governing pre-employment drug testing, including laws in states that limit or prohibit testing for certain substances. 


5. Sensitive Personal Information 

Certain categories of personal information collected during the hiring process are treated as sensitive and are subject to heightened protections: 


5.1 Equal Employment Opportunity (EEO) Data 

EEO information, including race, ethnicity, gender, disability status, and veteran status, is collected voluntarily and solely for purposes required or permitted by applicable law, including compliance with federal and state EEO reporting obligations. EEO data is stored separately from general application materials, is accessible only to HR personnel with a compliance function and is never used in individual hiring decisions.


5.2 Background and Criminal History Information 

Background screening results, including criminal history information where applicable, are used solely to evaluate fitness for the position applied for and are handled in compliance with the FCRA and applicable "ban the box" or fair chance hiring laws. 


5.3 Drug Testing Results 

Drug test results are treated as confidential medical information and are accessible only to HR personnel and hiring managers directly involved in the applicable hiring decision, and to authorized third-party administrators. 


6. Disclosure of Applicant Information 

Applicant information may be accessed or disclosed to the following categories of recipients for the purposes described in this Policy: 

  • Human Resources personnel and authorized recruiters 
  • Hiring managers participating in the hiring process for the specific position applied for 
  • First Advantage (background screening) and authorized drug testing administrators 
  • Other third-party service providers supporting recruiting, onboarding, or related functions, subject to the contractual obligations described below 
  • Government agencies or regulators, as required by applicable law 

All authorized third-party service providers are contractually obligated to implement and maintain security measures at least equivalent to those of the Company. Third parties are strictly prohibited from retaining, using, or disclosing applicant personal information for any purpose other than providing contracted services to Northwest Hardwoods.


The Company does not sell applicant personal information. The Company does not share applicant personal information with third parties for their own direct marketing purposes. 


7. Applicant Accounts 

Applicants may create and maintain applicant accounts through the Company's recruiting platform in order to apply for positions, update information, monitor application status, and apply for future employment opportunities. Applicants are responsible for maintaining the confidentiality of login credentials associated with their applicant accounts. The Company is not responsible for unauthorized access to applicant accounts resulting from an applicant's failure to safeguard their credentials. 


8. Data Security 

Northwest Hardwoods maintains reasonable and appropriate administrative, technical, and organizational safeguards designed to protect applicant information against unauthorized access, disclosure, misuse, alteration, or destruction. These safeguards include, without limitation: 

  • Encryption of sensitive personal information in transit and at rest 
  • Access controls limiting access to personal information to authorized personnel 
  • Employee training on data handling and privacy obligations 
  • Vendor due diligence and contractual security requirements for third-party service providers 
  • Periodic review of security policies and procedures 

No data transmission or storage system can be guaranteed to be completely secure. Applicants transmit information at their own risk. 


In the event of a confirmed security incident resulting in unauthorized access, disclosure, or loss of an applicant's personal information, the Company will notify affected individuals and relevant regulatory authorities in accordance with applicable state and federal data breach notification laws. 


9. Retention of Applicant Information 

Applicant information will be retained for the period required by applicable law and for legitimate business purposes, including consideration for future employment opportunities. Unless an applicant requests deletion where permitted by law, or unless a longer retention period is required by law, the Company will generally retain applicant information for no longer than twelve (12) months from the date of submission or last activity on the applicant's account. 


Certain information may be retained beyond this period as necessary to comply with legal obligations (including FCRA, EEOC, and applicable state recordkeeping requirements), resolve disputes, enforce agreements, or maintain required business records. 


10. Applicant Rights 

Subject to applicable law and legal limitations, applicants may have the right to: 

  • Request access to personal information the Company has collected about them 
  • Request correction of inaccurate personal information 
  • Request deletion of personal information, subject to applicable retention obligations and legal exceptions 
  • Withdraw consent where consent is the applicable legal basis for processing (note: withdrawal does not affect processing already completed) 

Requests regarding applicant information may be submitted to: 


Human Resources Department
Northwest Hardwoods, Inc.
Email: HR@nwh.com
18383 Preston Road, Suite 500, Dallas, TX 75252 


The Company will respond to verifiable rights requests within the timeframe required by applicable law. The Company may require verification of identity before processing certain requests. 


11. Additional Disclosures for California Applicants 

For applicants residing in California, Northwest Hardwoods provides the following additional disclosures pursuant to the California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"), California Civil Code §1798.100 et seq. 


11.1 Categories of Personal Information Collected 

NWH may collect the following categories of personal information from California applicants: identifiers; contact information; employment and education history; professional qualifications and certifications; internet or other electronic network activity information relating to use of the recruiting platform; background screening information where permitted by law; and sensitive personal information as described in Section 5. 


11.2 Purposes of Collection 

Such information is collected solely for recruiting, hiring, employment consideration, legal compliance, and related business purposes as described in Section 3 of this Policy.


11.3 California Consumer Rights 

California applicants have the right to: (a) know what personal information is collected, used, shared, or sold; (b) request deletion of personal information, subject to applicable exceptions; (c) request correction of inaccurate personal information; (d) opt out of the sale or sharing of personal information (NWH does not sell or share personal information as defined under the CPRA); and (e) limit the use and disclosure of sensitive personal information to the purposes authorized by law. 


To exercise California rights, contact HR@nwh.com, (800) 553-5346, or the mailing address listed in Section 10. 


11.4 Shine the Light Disclosure 

Pursuant to California Civil Code §1798.83, Northwest Hardwoods does not share applicant personal information with third parties for those parties' own direct marketing purposes. 


11.5 Non-Discrimination 

NWH will not discriminate against applicants for exercising their California privacy rights. 


12. Additional Disclosures for Applicants in Other States 

To the extent Northwest Hardwoods recruits or employs individuals in states with applicable comprehensive privacy laws, applicants in those states may have rights similar to those described in Section 10. These states currently include, without limitation, Texas, Colorado, Virginia, Connecticut, Oregon, Montana, Nebraska, New Hampshire, New Jersey, Delaware, Iowa, Indiana, and Tennessee, among others. 


Applicants in these jurisdictions may submit rights requests using the contact information in Section 10. The Company will respond in accordance with applicable law. 


13. Governing Law 

This Policy is governed by and construed in accordance with the laws of the State of Texas, without regard to conflict of law principles, except to the extent superseded by applicable federal law or the mandatory provisions of the law of any other jurisdiction in which NWH operates. 


14. Updates to This Policy 

Northwest Hardwoods reserves the right to amend, modify, or update this Applicant Privacy Policy at any time. Any updates will be posted through the recruiting platform or otherwise made available to applicants, along with an updated effective date. Applicants are encouraged to review this Policy periodically. Material changes to this Policy will be communicated to applicants with active accounts through the recruiting platform or by email where practicable. 


15. Contact Information 

For questions about this Policy, or to submit a privacy rights request, please contact: 


Human Resources Department
Northwest Hardwoods, Inc.
Email: HR@nwh.com
18383 Preston Road, Suite 500, Dallas, TX 75252