THE PACIFIC CLUB

POLICY RE CONFIDENTIAL JOB APPLICANT DATA

Purpose

This Policy Re Confidential Job Applicant Data (“Policy”) outlines the procedures and expectations for handling, storing, and protecting personal data collected from job applicants. The Pacific Club is committed to safeguarding confidential information pertaining to individuals applying for employment and to ensuring compliance with all applicable laws regarding the protection of job applicants’ confidential information.

Scope

This Policy applies to all employees, contractors, recruiters, and third-party vendors who collect, process, or have access to job applicant data during the recruitment and hiring process.

Definition of “Confidential Job Applicant Data”

“Confidential Job Applicant Data” refers to any personal information submitted by a candidate and/or obtained from third parties regarding the candidate during the recruitment process, including but not limited to:

· Full name, contact details, home addresses, and personal email addresses 

· Identifiers, such as name, government-issued identifier (e.g., Social Security number (“SSN”) and/or other unique identifiers (e.g., employee ID, driver license numbers, etc.)

· Employment references (names and contact information)

· Emergency contact information and/or dependent information

· Interview notes and assessments

· Background check results (where applicable) and correspondence/follow-up information re same

· Any sensitive data (e.g., demographic and/or EEO data, immigration status and/or medical or mental information), if voluntarily disclosed and lawfully collected. Nothing in this Policy prevents the Company from disclosing and/or reporting this information to government authorities if required under applicable laws.

Collection and Use

Confidential Job Applicant Data must only be collected for legitimate recruitment purposes. Data collected must be relevant and limited to what is necessary for evaluating the candidate’s suitability for the role. Confidential Job Applicant Data should only be reviewed and used by authorized personnel involved in the hiring process.

Confidentiality and Access Control

All Confidential Job Applicant Data must be treated as confidential and stored securely (e.g., encrypted systems, password protection, secure filing cabinets).

Access to Confidential Job Applicant Data is restricted to Human Resources (“HR”) personnel, hiring managers, and others directly involved in recruitment and hiring decisions.

Sharing of Confidential Job Applicant Data with third parties (e.g., background check providers) must be based on a lawful basis and with appropriate data processing agreements in place.

Data Retention

Confidential Job Applicant Data will be retained only for as long as necessary to complete the recruitment process and to comply with applicable legal or regulatory obligations. If a candidate is offered and accepts employment, Confidential Job Applicant Data will be maintained as part of the candidate (now employee’s) confidential personnel file.

Unsuccessful Confidential Job Applicant Data will typically be retained for a period of four (4) years from the date a hiring decision was made for the position for which the candidate applied.

Data Disposal

Upon expiration of the Data Retention period, applicant data will be securely destroyed or anonymized in accordance with the Company’s procedures. Paper records will be shredded, and electronic files or information will be permanently deleted from all storage systems, including backups.

Breach Reporting and Accountability

Any suspected or actual breach of Confidential Job Applicant Data must be reported immediately to the HR Department or another appropriate individual, e.g., the President of Pacific Club. The Pacific Club will investigate any breach and take appropriate action, which may include disciplinary measures and notification to affected individuals and regulatory bodies if required.

Compliance

All employees involved in recruitment will receive training on data privacy and this Policy.

Regular audits may be conducted by the Pacific Club to ensure ongoing compliance.

Effective Date: 6/26/2025

Approved By: Silvia Diaz - Director Human Resources