Effective Date: December 21, 2022
The purpose of this Workforce Privacy Notice (“Workforce Privacy Notice”) is to inform Tandem Diabetes Care, Inc. (“Tandem,” “we,” “ us,” or “our”) California Workforce Members of our practices regarding the collection, use, and disclosure of their personal information (“Workforce Member Personal Information”), and the rights they have under the California Consumer Privacy Act, as amended (the “CCPA”). “Workforce Member” means all employment relationships, including current and former Tandem: full-time employees, part-time employees, temporary employees, interns, and contractors. For more information about Tandem’s privacy practices, please review our Privacy Policy.
As used in this Workforce Privacy Notice, the term “Workforce Member Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with Tandem Workforce Members. Workforce Member Personal Information does not include information that is publicly available, de-identified, or aggregated.
Unless otherwise noted, the disclosures herein cover our activities in the twelve (12) months preceding the Effective Date, as well as our current practices.
Tandem may collect, use, and disclose Workforce Member Personal Information for business purposes consistent with applicable laws as identified below. Where Tandem transfers applicable Workforce Member Personal Information to recipients, such as our service providers, it does so for the same business purposes described below. These examples may vary depending on the nature of your interactions with us.
| Category of Workforce Member Personal Information | Business Purposes for Collection, Use, or Disclosure | Categories of Recipients to whom Workforce Member Personal Information is Disclosed for a Business Purpose |
|---|---|---|
| Identifiers such as name, alias, title, telephone number, email address, mailing address, IP address, online identifiers, signature, professional license numbers.. | We will use this information to assess your eligibility for employment, to onboard and enroll you as an employee, to process payroll, to communicate with you, to manage job duties and evaluate performance, to provide you with employee benefits, to address grievances, for security and fraud detection/prevention, for tax purposes, for internal company research, to comply with legal or regulatory requirements or as required by company policy. | Data analytics providers, employee benefit providers, payroll and timekeeping providers, stock and 401(k) providers, travel agencies and expense management providers, security providers, background check vendors, information technology vendors, employee recognition programs, employee education providers, outside human capital management firms, outside legal counsel, and state or federal governmental agencies. |
| Personal information described in Cal. Civ. Code § 1798.80(e) such as name, physical and electronic signature, address, telephone number, bank account numbers, Social Security Number, physical characteristics, education, employment, employment history, medical and health insurance information. | We will use this information to assess your eligibility for employment, to onboard and enroll you as an employee, to process payroll, to communicate with you, to manage job duties and evaluate performance, to provide you with employee benefits, to address grievances, for security and fraud detection/prevention, for tax purposes, for internal company research, to comply with legal or regulatory requirements or as required by company policy. | Data analytics providers, employee benefit providers, payroll and timekeeping providers, stock and 401(k) providers, travel agencies and expense management providers security providers, background check vendors, information technology vendors, employee recognition programs, employee education providers, outside human capital management firms, outside legal counsel, and state or federal governmental agencies. |
| Protected classification characteristics such as age and date of birth, marital status, race, ethnic origin, sex, gender, gender identity, religion or creed, military or veteran status, medical condition, disability, marital status. | We will use this to conduct equal opportunity and diversity monitoring where permitted or required by law, to onboard and enroll you, and to comply with our obligations to provide leaves or reasonable accommodations under states and federal laws. | Data analytics providers, employee benefit providers, payroll and timekeeping providers, stock and 401(k) providers, travel agencies and expense management providers security providers, background check vendors, information technology vendors, employee recognition programs, employee education providers, outside human capital management firms, outside legal counsel, and state or federal governmental agencies. |
| Internet or other electronic network activity information such as browser type and language, operating system, website access time, duration of visit, information related to your interactions with our websites, social media pages, emails, online chat, text message communications, and advertisements. | We will use this information to monitor your compliance with our internal policies and procedures, to investigate security breaches and misuse of computer equipment and systems, and to protect the safety of employees and third parties. | Data analytics providers, security providers, information technology vendors, outside legal counsel, and state or federal governmental agencies. |
| Geolocation data as your geographic location inferred from your device IP address. | We will use this information to manage job duties and evaluate performance, for security and fraud detection/prevention or as required by company policy. | Security providers, information technology vendors, outside legal counsel, and state or federal governmental agencies. |
| Sensory data, such as security camera recordings, photographs. | We will use this information to manage workplace and public safety and health; for employee communications; and for marketing and social media. | Security providers, information technology vendors, outside legal counsel, and state or federal governmental agencies. |
| Professional or employment-related information such as skills, qualifications, work experience, references, recommendations, and other information included in a resume, CV, application form, or cover letter. | We will use this information to assess your eligibility for employment, to onboard and enroll you as an employee, to process payroll, to communicate with you, to manage job duties and evaluate performance, to provide you with employee benefits, to address grievances, for security and fraud detection/prevention, for tax purposes, for internal company research, to comply with legal or regulatory requirements or as required by company policy. | Data analytics providers, security providers, background check vendors, information technology vendors, outside human capital management firms outside legal counsel, and state or federal governmental agencies. |
| Workforce Member Personal Information that does not directly fall within the categories listed in the CCPA including citizenship status, emergency contact information, tax information, applications for benefits, vaccination status and drug and alcohol screening. | We will use this information to assess your eligibility for employment, to onboard and enroll you as an employee, to process payroll, to communicate with you, to manage job duties and evaluate performance, to provide you with employee benefits, to address grievances, for security and fraud detection/prevention, for tax purposes, for internal company research, to comply with legal or regulatory requirements or as required by company policy. | Security providers, background check vendors, employee benefit providers, payroll and timekeeping providers, stock and 401(k) providers, travel agencies and expense management providers, outside human capital management firms, outside legal counsel, and state or federal governmental agencies. |
Tandem may collect, use, and disclose sensitive Workforce Member Personal Information for business purposes consistent with applicable laws as identified below. Where Tandem transfers applicable sensitive Workforce Member Personal Information to recipients, such as our service providers, it does so for the same business purposes described below. These examples may vary depending on the nature of your interactions with us.
| Category of Sensitive Workforce Member Personal Information | Business Purposes for Collection, Use, or Disclosure of Sensitive Workforce Member Personal Information | Categories of Recipients to whom Sensitive Workforce Member Personal Information is Disclosed for a Business Purpose |
|---|---|---|
| Workforce Member Personal Information that reveals their social security number, driver’s license, or passport number. | We will use this information to confirm eligibility and qualifications, perform background checks, provide employee benefits, and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws. | Background check vendors, human resources and information technology vendors, outside legal counsel, state or federal governmental agencies, credit bureaus, payroll processors, stock and 401(k) administrators. |
| Workforce Member Personal Information that reveals their racial or ethnic origin, religious or philosophical beliefs, or union membership. | We will use this information to confirm eligibility, qualification, and background checks, and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws. | Background check vendors, human resources and information technology vendors, outside legal counsel, state or federal governmental agencies, credit bureaus, and payroll processors. |
| Precise geolocation data. | We will use this information to process reimbursements and payroll, to manage job duties and evaluate performance, and for security and fraud detection/prevention. | Human resources and information technology vendors, outside legal counsel, state or federal governmental agencies, payroll and expense reimbursement processors. |
We may disclose each of the categories of Workforce Member Personal Information identified above to the respectively identified categories of recipients for operational or business purposes consistent with the purposes for collection or use designated, as is reasonably necessary and proportionate to achieve those purposes, or for another purpose that is compatible with the context in which the Workforce Member Personal Information was collected including, but not limited to:
In addition to the other purposes for collection, use, and disclosure of Workforce Member Personal Information described in this Workforce Notice, we may collect, use, and disclose Workforce Member Personal Information as required by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our or others’ rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions/investigations. Likewise, we may use and disclose Workforce Member Personal Information to other parties in connection with the sale, assignment, merger, or reorganization.
We may collect Workforce Member Personal Information and sensitive Workforce Member Personal from the following sources:
We may also collect publicly available information about you, including information that is lawfully made available to the general public from federal, state, or local government records.
We do not sell Workforce Member Personal Information or share it for cross-context behavioral advertising. If you also interact with us as a consumer, please review our California Consumer Privacy Notice at tandemdiabetes.com/legal/privacy for more information about our practices in that context.
We will store Workforce Member Personal Information for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the Workforce Member Personal Information was collected, or as may be required or permitted under applicable law. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and the applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period we will remove Workforce Member Personal Information from our systems and records or take appropriate steps to properly anonymize, deidentify, or aggregate it, where legally applicable.
If you are a California resident, you are entitled to the following rights. To exercise any of these rights, please submit a request by email to hrsupport@tandemdiabetes.com or call us at 1-858-366-6900. Please note that if you submit a request to know, request to delete, or request to correct, you will be asked to provide 2-3 pieces of Workforce Member Personal Information that we will match against our records to verify your identity. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed.
Right to Know. You have the right to know what Workforce Member Personal Information we have collected about you, which includes:
Right to Delete Your Personal Information. You have the right to request that we delete Workforce Member Personal Information we collected from you, subject to certain exceptions.
Right to Correct Inaccurate Information. If you believe that Workforce Member Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.
Right to Opt Out of Sales and Sharing of Personal Information. We do not sell Workforce Member Personal Information or share it for cross-context behavioral advertising.
Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use or disclose sensitive Workforce Member Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.
Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us, including retaliation against you as an employee, job applicant, or independent contractor.
We use appropriate administrative, technical, physical, and organizational measures to protect the Workforce Member Personal Information we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your Workforce Member Personal Information. This includes managerial measures, including establishment and implementation of internal management plan and periodic training for employees; technical measures, including controlling access rights to personal information processing systems and encryption of important data; and physical measures, including external security and management of system servers. While we implement security measures designed to be appropriate to the relevant risks, please note no data transmission over the internet or any wireless network can be guaranteed as being 100% secure.
We reserve the right to amend this Workforce Notice at any time without advance notice to address future developments of Tandem, or changes in industry or legal trends. We will post the revised Workforce Notice at tandemdiabetes.com/legal/privacy. You can determine when the Workforce Notice was revised by referring to the “Effective Date” legend on the top of this Workforce Notice. Any changes will become effective upon the posting of the revised Workforce Notice.
Please contact Human Resources with any questions.
Tandem Diabetes Care, Inc.
Attn: Human Resources
12400 High Bluff, Ste. 100
San Diego, CA 92130
858-366-6900
hrsupport@tandemdiabetes.com