Walmart Associate Information Privacy Policy

and last updated on January 01, 2020 02:00 AM

Effective January 1, 2020

Effective January 1, 2020

Walmart Associate Information Privacy Policy Summary

At Walmart, we recognize the tremendous value of our associates. Therefore, we place great importance in managing your information in accordance with our core value of respect for the individual. As a Walmart associate, you are in a unique situation because you are also on some occasions our customer. Because of this, the information Walmart collects about you falls into two categories: your customer information and your associate information. When you shop in Walmart stores or make purchases from Walmart.com, you are acting as a customer of Walmart, and your personal information is protected by the commitments that we make in our customer privacy policy. When you are at work or using company-owned equipment, the information that we use and collect about you is considered “associate information.” This policy provides increased transparency around how Walmart manages and uses associate information.

Associate information is personal information about our associates that identifies you or reasonably can be linked to information that identifies you. For example, we may collect contact and other information, like your name, email and physical addresses, phone numbers, social security numbers, and other information necessary for business purposes like administering payroll, taxes, and benefits. Associate information does not include publicly available information.

Scope

This policy applies to all current and former Walmart associates and describes the collection, use, and sharing of associate information, as well as the choices and obligations you have with respect to your information. In this policy, Walmart refers to all Walmart Inc. corporate family of companies. This policy does not supersede existing policies. Walmart reserves the right to change this policy at any time. Associates should check OneWalmart regularly for updates.

Pledge of Accountability

Walmart takes steps to ensure our associates and business partners manage your personal information properly to maintain your trust. We have designated associates who are accountable for compliance with this Walmart Associate Privacy Policy. We expect associates and business partners that handle associate information to take reasonable measures to maintain the confidentiality of your information and to do so in accordance with our policies and the law.

Information Collection – What We Collect and How We Collect It

Information We Collect

We may collect the following categories of personal information. Not all categories may be collected about every individual:

  • Personal identifiers, such as name and address
  • Device and online identifiers and related information, such as telephone number and email address
  • Internet, application, and network activity, such as cookie IDs and browser visits
  • Government identifiers, such as national identification numbers and driver’s license numbers
  • Demographic information, such as age and date of birth
  • Financial information, such as bank account and routing numbers
  • Health and health insurance information, such as prescription numbers and health insurance identification numbers
  • Characteristics of protected classifications under state or federal law, such as gender and race
  • Biometric information, such as imagery of the iris, retina, and fingerprints
  • Location information, such as geo-location information
  • Audio, visual, and other sensory information, such as audio and video recordings
  • Employment information, such as occupation, title, licenses and professional memberships
  • Background and criminal information, such as background checks and criminal convictions consistent with applicable law
  • Education information, such as degree and schooling information
  • Individual preferences and characteristics, such as information related to any assessment you may take as part of the interview screening process upon hire or during your tenure for promotional opportunities

How We Collect Associate Information

Information Collected from You
Walmart collects personal information directly from you as part of your employment. For example, information that you give us when you fill out an employment application or enroll in benefits programs, or it can be information that you give us when you interact with services such as OneWalmart or fill out your Workplace profile. We may also collect photographs or audio/visual recordings on Walmart property, or during events and activities relating to your employment with Walmart.

Information Collected Automatically
We collect information from you automatically when you use certain websites Walmart operates for our associates, like One.Walmart.com. This information may not identify you directly. For example, we may collect IP address, browser or operating system information, and referring website. Our websites may use cookies, which are small text files stored on your computer that help us to maintain your session or provide other interactive features. You can turn off cookies through your browser. However, turning off cookies may limit some functionality of the site, such as changing the layout of your personalized content. The site may also use web beacons, which allow us to know if you visited a certain page. Additionally, we collect information from you when you use company equipment, systems and applications. For more information and more detailed guidance on the use of Walmart systems, please refer to the “Additional Resources” section below.

Information Collected from Other Sources
We receive information about you from third party sources to assist us with employment-related activities, and other legal matters. For example, we may collect information from employment background agencies for the purpose of conducting a background check. Examples of the types of information contained in a background check may include your criminal, employment, and educational history, as well as information about your character, general reputation, personal characteristics, mode of living, credit standing, and more. Before requesting a background check, Walmart will obtain your informed and specific consent by asking you to sign a Fair Credit Reporting Act Authorization and Disclosure Form. More information, including market-specific details, can be found in “Additional Resources”.

Use of Associate Information

We will use your information for the following purposes. We will not use your associate information to market non-employment related products or services to you without your consent.

  • To fulfill requests and obligations related to your employment
  • To create and maintain records related to your employment
  • To conduct auditing and monitoring of transactions and engagement
  • To protect the security and integrity of our systems, processes and our business, and help prevent fraud
  • To update our operational and technical functionality
  • To conduct business analysis, such as analytics, projections, identifying areas for operational improvement
  • To conduct research and development
  • To fulfill our legal function or obligations
  • To conduct recruiting and for employment purposes

Employment Purposes

We will collect personal information about you or your dependents relating to your working relationship with Walmart. We will use the information for employment purposes and in the context of our employment relationship with you, such as recruiting and hiring, enrolling you in benefits and administering payroll, and for evaluation and training purposes.

  • Recruiting and Hiring – We use your personal information to consider your skills, qualifications and interests in connection with our employment opportunities; to communicate with you and inform you of career opportunities; to conduct background checks if you are offered a job; to improve our recruiting and hiring process.
  • Benefits – We will use your information to enroll you, deliver, and communicate with you about the various benefit plans we offer. Walmart offers associates many different benefits and uses associate information in different ways depending on the type of benefit program. For example:

Associate Discount Cards – you are automatically enrolled to receive an Associate Discount Card once you have met the eligibility requirements. Walmart may monitor or review your use of the associate discount card as a part of an investigation of potential misuse or abuse of the benefit.
Health Benefits – Associate information such as date of hire, job classification, medical information about you and your dependents, and more, can be used to determine your eligibility for health benefits as well as to help you select and enroll in the benefits programs that are right for you and your family. If you choose to enroll in a healthcare plan offered by Walmart, it is important to note that your plan does not share associate information collected in the course of your medical care with Walmart unless it is required or permitted by law. One example of this is compliance with the Affordable Care Act (ACA), which requires an employer to report that employees are enrolled in a healthcare plan, so the plan provider must share information necessary for Walmart to comply with ACA requirements.
Fitness Membership – Use of the Walton Life Fitness Pass (WLFP) is optional. If you decide to be a member, we will collect personal information about you and your dependents in order to enroll you in membership, deduct the membership fee from your paycheck, and otherwise administer your membership. Aggregated information from sign-in times and class participation may be used to ensure that programs, locations and equipment fit the needs of WLFP members.

  • Payroll – We will use information you have provided, such as direct deposit or banking information, to administer payroll services.
  • Job Performance and Career Management – We will use your information for the purposes of evaluating performance, managing job related training, building career-path development insights and tools, and optimizing job roles.
  • Walmart Participation in State and Federal Worker and Business Incentive Programs – We may use your information when it is required to participate in tax and employment incentive programs offered by state and federal governments. In order to verify that an associate qualifies Walmart for a tax or other incentive, Walmart may be required to submit personal information, including Social Security Numbers (or other such government identifiers), to the government entity or their service provider.
  • Legal Purposes – We may use your information to prepare any legal claim or defense necessary to protect the interests of Walmart, our associates, and our customers.
  • Investigative Purposes – We may use your information to conduct investigations related to company policies.

Participation in Voluntary Associate Programs

We offer associates many opportunities to participate in new initiatives and programs designed to add value to the workplace experience, for example the Associate Engagement Survey (AES) and Associate Giving Programs. Participation in these programs is voluntary, and the information that you share with us or the service providers that enable us to provide these programs will be handled responsibly and in accordance with this policy. There are certain programs where personal information of all associates is shared with the service provider prior to any enrollment by the associate. In such cases we require by contract that the benefit provider handle the information responsibly and in accordance with conditions specified by Walmart.

Monitoring and Protection

Cameras
To ensure the safety and security of our customers, associates and assets, closed circuit television and cameras are used throughout Walmart facilities. These cameras are used for purposes such as safety and security, asset protection, operations improvement, and deterrence and investigation of misconduct. Cameras will only be used in areas where an individual has an expectation that the individual could be recorded.

Equipment and Systems
We have a reasonable interest in ensuring that company equipment and systems, as well as data, are protected and used properly. Accordingly, to the extent allowed by applicable law, we monitor or record any and all use of company equipment and systems, including use for personal purposes.

For more information, including market-specific policies, see “Additional Resources.”

Sharing and Joint Use of Associate Information

Sharing with the Walmart Business
Associate information may be shared with our business teams or within our corporate family of companies, as permitted by law, when it is determined that there is a benefit for you or our business. Associate information must be managed and protected in accordance with Walmart policies. In addition, Walmart takes appropriate technical, organizational, and legal steps to protect your information. For example, access to information is granted on a need to know basis and is given only to persons who need relevant information to accomplish their properly assigned job responsibilities.

Sharing with Service Providers
From time to time, we may utilize service providers to administer certain programs, benefits, or administrative functions on behalf of Walmart. We require our service providers to keep your personal information confidential.

Sharing for Legal Requirements and Protection of Walmart and Others
We may share your personal information in other special circumstances, which include situations when sharing is required by law, or we believe sharing will help to protect the safety, property, or rights of Walmart, our customers, our associates, or other persons. Examples include:

  • Protecting the health or safety of associates or customers;
  • Addressing crimes committed on Walmart property;
  • Identifying and addressing fraud or financial risk;
  • Providing personal information to law enforcement at their written request;
  • Responding to a search warrant or other valid legal inquiry

Associate Rights: Choice, Access, Correction, Questions, and Concerns

You may have additional rights beyond those described below available to you in your market. Please see “Additional Resources” for more information.

Associate Choices for Communications
Associates may elect to receive certain communication relating to their employment through email, phone, text message, and/or physical mail. Teams that manage associate information may communicate with you in various ways, so you may need to review your communications choices in several different places.

Associate Right of Access, Correction, and Deletion of Information
As an associate of Walmart, we will provide you with reasonable access to your associate information, an opportunity to correct inaccurate information, and an opportunity to request deletion of your information, as appropriate under local law. Please see “Additional Resources” for more information.

We will not discriminate against you for exercising your rights.

Contacts for Questions and Concerns Regarding this Policy
You may discuss questions or concerns about this policy with your management team or your HR business partner. Additionally, you may contact the benefits department, payroll department, or any other group that maintains information about you through this process. Up to date phone numbers are maintained on OneWalmart. If you have concerns about a breach of information you may call the EOC at 479-277-1001. If you have a concern you may report it to Global Ethics through www.walmartethics.com, ethics@wal-mart.com, or 1-800-WM-ETHIC.

Additional Resources
U.S. Market:
Company-Issued Equipment & Systems Usage Policy
BYOD Agreement
Background Checks Policy
Closed Circuit Television and Camera Policy
Associate Access to Personnel Files
Discrimination and Harassment Prevention Policy

This policy does not create an express or implied contract of employment or any other contractual commitment. Walmart may modify this policy at its sole discretion without notice, at any time, consistent with applicable law. Employment with Walmart is on an at-will basis, which means that either Walmart or the associate is free to terminate the employment relationship at any time for any or no reason, consistent with applicable law.

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