Northwestern Mutual California workforce privacy notice
Last Revised: January 1, 2020
Collection of Personal Information
This privacy notice for California residents supplements the information contained in the Online Privacy Statement and related disclosures of The Northwestern Mutual Life Insurance Company and its subsidiaries (e.g., Northwestern Mutual Investment Management Company, LLC, Northwestern Mutual Wealth Management Company, Northwestern Mutual Investment Services, LLC, Mason Street Advisors, LLC)(collectively, "NM," "we," "us," or "our") and applies solely to visitors, users, and others who reside in the State of California who are job applicants, employees, independent contractors, corporate officers and directors ("California workforce" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 ("CCPA") and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
When this Privacy Notice Does Not Apply to Your Personal Information
Please note that this Privacy Notice does not apply to your Personal Information when we already protect it under other laws such as the Gramm, Leach Bliley Act (GLBA), the California Financial Information Protection Act, the Health Insurance Portability and Accountability Act (HIPAA), the Fair Credit Reporting Act (FCRA), and/or the Driver's License Protection Act. It does not apply to Personal Information collected with respect to the products and services we provide as a service provider, such as insurance products (Life, Disability, Long-term Care, annuities), investment products (e.g., investment funds, retirement, etc.), and financial planning services, or in the context of business-to-business relationships. For a description of our privacy practices as well as your rights and choices in these instances, please go to Privacy Notices .
Also, this Privacy Notice does not apply to Personal Information collected in the context of any contractual relationship with our sales force, including applicable network offices. To understand more about our privacy practices in this instance, go to Northwestern Mutual California Agents Privacy Notice .
Therefore, the rights and choices described in this California Workforce Privacy Notice do not apply to Personal Information collected in the above contexts.
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident, household or device ("Personal Information"). In particular, in the year before the date this policy was issued or last updated, we may have collected the following categories of personal information from our California workforce:
| Category of Personal Information | Examples (not all inclusive) |
|---|---|
| A. Personal Information and Identifiers | Name, alias, Social Security Number, date of birth, signature, home address, e-mail address(es), telephone number(s), driver's license or state identification card number, passport number, and other similar identifiers. |
| B. Demographics | Age, race, ethnicity, gender identification, medical condition, disability status, citizenship, veteran or military status, marital status, family member information. |
| C. Professional or Employment Information | Salary/compensation, benefits, beneficiary designations, talent management, disciplinary action, employment contract(s), employment history, performance reviews, professional designations, personnel files, training, visa status, business expenses, use of company products, and pre-hire documents (such as job applications, resumes, background check information, drug test information, and candidate evaluations). |
| D. Education Information | School records, school(s) attended, dates attended, degree(s) earned, academic achievements. |
| E. Financial Information | Retirement account information, bank accounts, investment or brokerage accounts, information on personal property and real estate, student loans, insurance, information regarding estate or tax planning, debts, trusts, credit or debit card number(s), legal issues (e.g., child support, alimony, wage garnishments and subpoenas), and benefits information. |
| F. Medical Information | Medical history, medical questionnaires, information regarding physical, mental and/or behavioral health, genetic information, wellness activities and subsidies, health insurance information, information regarding payment for healthcare services. |
| G. Biometric Information | Fingerprints, facial scans, eye scans, voice recognition, typing cadence, and any other biometric identifier that we may use for security, other operational purposes, or our voluntary wellness program. |
| H. Internet or Network Activity | Browser history, search history, IP address, mobile device identifier, cookies, use of IT resources, interaction with website, app, advertisements. |
| I. Geolocation Data | GPS coordinates, location-tracking information, physical location or movements. |
| J. Profile Information | Profiles reflecting a person's preferences, such as interests, hobbies, physical characteristics or description, characteristic tendencies, behaviors, attitudes, or aptitudes, including inferences drawn from any Personal Information. |
| K. Product Information | Policy/account number(s), policy/account values, beneficiary, ownership arrangements, transaction history. |
| L. Audiovisual Information | On-site security cameras, pictures, video and audio recordings |
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
- Workforce Management such as:
- To evaluate individuals for a position with us when applying for a position or we receive the individual's information related to a position at NM
- To comply with state and federal laws requiring employers to maintain certain records
- To process payroll and manage applicable tax withholding and reporting
- To administer and maintain group health insurance benefits, additional wellness programs, 401(k) and/or retirement plans, life insurance, disability insurance, leave programs and additional fringe benefit programs
- To manage and/or analyze all aspects of employee performance of their job duties and employment, including, but not limited to, training, talent management, periodic reviews, performance tracking, promotions, and discipline
- For surveys, research, analysis and strategic development to implement, maintain and promote an engaging work experience at NM, such as the creation of Employee Resource Groups
- To review and audit employee interactions with the Field and NM's customers and business partners
- For employee and facility security
- To support information technology services to the workforce
- For emergency training and emergency response
- Research & strategic development such as:
- Information collected for business, product, strategy, and technological development, excluding Marketing and advertising activities
- Detecting and Protecting such as:
- Detecting and protecting against security incidents and malicious, deceptive, fraudulent or illegal activity, or violations of NM policies or the law
- For fraud and crime prevention
- For information protection and cybersecurity
- Legal/Compliance/Regulatory such as:
- To meet additional legal, compliance, and regulatory requirements and to defend Northwestern Mutual's rights and property
- Online auditing such as:
- Auditing related to a current interaction with our California workforce and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with standards
- Debugging such as:
- To debug errors in systems
- Backups and Archives such as:
- For disaster recovery, business continuity and record keeping obligations
Rights to your Personal Information
You have a number of legal rights when it comes to your Personal Information, including the right to be informed about the Personal Information we collect and the purposes for which we use your Personal Information.
Your rights under certain applicable laws, such as rights to request access to or deletion of all Personal Information we may hold about you do not apply to employees and other personnel at this time. However, under other laws, you may have access to certain personnel details to verify the accuracy of or update your data, or you may have other privacy rights as an employee, and you can contact your local NM HR representative for more information and assistance.
As further detailed in our polices on information security, you have no right to privacy in your use of NM information technology resources, including emails and communications for work purposes which constitute NM business records and which are monitored and may be reviewed or disclosed at any time without further prior notice for compliance, legal and other operational needs.
Changes to Our Privacy Notice
We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will update our website and policy Last Revised date accordingly.
Notice for Our California Workforce with Disabilities
We are committed to providing our California workforce with disabilities with the same level of access to this Privacy Notice that is available to our California workforce without disabilities. This notice is compatible with standard screen readers. If you need further assistance, please contact 800-950-4644.
Contact Information
If you have any questions or comments about this Privacy Notice or need accommodation to access this Privacy Notice, you may contact us at:
Toll Free Phone: 866-950-4644, when prompted say California Consumer Privacy Act
Online: California Consumer Privacy Act (CCPA) Request to Know and/or Delete.