Organizations Covered by this Policy
Nutrien is a family of companies with operations both inside and outside of Canada.
The Nutrien family (“Nutrien Family”) includes the parent company, Nutrien Ltd. and its affiliated entities, including a Canadian operating partnership.
Policy of Compliance
What is Personal Information?
What Personal Information Do We Collect?
We collect and maintain different types of personal information in respect of those individuals who seek to be, are, or were employed by us. This includes personal information contained in:
- resumes and/or applications;
- references and interview notes;
- photographs and video;
- letters of offer and acceptance of employment;
- mandatory policy acknowledgement sign-off sheets;
- payroll information; including but not limited to social insurance number, pay cheque deposit information, and GRRSP/ESP information;
- wage and benefit information;
- forms relating to the application for, or in respect of changes to, employee health and welfare benefits; including, short and long term disability, medical and dental care;
- beneficiary and emergency contact information;
- background screening information; and
- drug test results.
In addition to the examples listed above, personal information also includes information such as name, home address, telephone, personal email address, date of birth, employee identification number and marital status, and any other information necessary to Nutrien's business purposes, which is voluntarily disclosed in the course of an employee's application for and employment with Nutrien. Personal information collected for employment purposes is considered “employment data.”
As a general rule, Nutrien collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions).
From time to time, we may utilize the services of third parties (including other members of the Nutrien Family) in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.
Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.
In the U.S., certain states require that we make specific disclosures regarding our collection and use of personal information. For additional information, that may apply based on your location, please see the State Specific Addenda below.
How Do We Use Personal Information?
Employment data is used and disclosed for our business purposes, including establishing, managing or terminating your employment relationship with Nutrien. Such uses include:
- determining eligibility for initial employment, including the verification of references and qualifications;
- administering pay and benefits;
- processing employee work-related claims (e.g. worker compensation, insurance claims, etc.)
- establishing training and/or development requirements;
- conducting performance reviews and determining performance requirements;
- assessing qualifications for a particular job or task;
- gathering evidence for disciplinary action, or termination;
- establishing a contact point in the event of an emergency (such as next of kin);
- complying with applicable labor or employment statutes;
- compiling directories;
- ensuring the security of company-held information;
- such other purposes as are reasonably required by Nutrien in connection with your employment; and
- for any additional purposes that we advise you of and for which we have a legal basis, which may for instance be your consent when such consent is required by law.
We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
The work output of Nutrien's employees, whether in paper record, computer files, or in any other storage format belongs to us, and that work output, and the tools used to generate that work output, are always subject to review and monitoring by Nutrien.
In the course of conducting our business, we may monitor employee activities and our premises and property. For example, some of our locations are equipped with surveillance cameras. These cameras are generally in high risk areas or plant sites. Where in use, surveillance cameras are there for the protection of employees and third parties, and to protect against theft, vandalism and damage to Nutrien's goods and property. Generally, recorded images are routinely destroyed and not shared with third parties unless there is suspicion of a crime, in which case they may be turned over to the police or other appropriate government agency or authority. Pursuant to our Acceptable Use of Computer Systems, Equipment, Infrastructure and Internet Systems Policy, we have the capability to monitor all employees' computer and e-mail use.
This section is not meant to suggest that all employees will in fact be monitored or their actions subject to constant surveillance. We have no duty to so monitor. It is meant to bring to your attention the fact that such monitoring may occur and may result in the collection of personal information from employees (e.g. through their use of our resources). When using Nutrien equipment or resources employees should not have any expectation of privacy with respect to their use of such equipment or resources.
When Do We Disclose Your Personal Information?
We may share your personal information with our employees, contractors, consultants and other parties (including other members of the Nutrien Family) who require such information to assist us with establishing, managing or terminating our employment relationship with you, including: parties that provide products or services to us or on our behalf and parties that collaborate with us in the provision of products or services to you. In some instances, such parties may also provide certain information technology and data processing services to us so that we may operate our business. We may share personal information with such parties both in and outside of your home jurisdiction, and as result, your personal information may be collected, used, processed, stored or disclosed in Canada and in the United States of America, and in some cases, other countries. Personal information is only transferred by us to another country, including within the Nutrien Family, if this is required or permitted under the applicable privacy legislation, in particular only in as far as a reasonable level of data protection is assured in the recipient country.
Further, your personal information may be disclosed:
- as permitted or required by applicable law or regulatory requirements. In such a case, we will endeavor to not disclose more personal information than is required under the circumstances;
- to comply with valid legal processes such as search warrants, subpoenas or court orders;
- as part of Nutrien's regular reporting activities to other members of the Nutrien Family (including outside of your home jurisdiction);
- to protect the rights and property of Nutrien;
- during emergency situations or where necessary to protect the safety of a person or group of persons;
- where the personal information is publicly available; or
- with your consent where such consent is required by law.
Notification and Consent
Privacy laws do not generally require Nutrien to obtain your consent for the collection, use or disclosure of personal information for the purpose of establishing, managing or terminating your employment relationship. In addition, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
To the extent that your consent is required, we will assume, unless you advise us otherwise, that you have consented to Nutrien collecting, using and disclosing your personal information for the purposes stated above (including any other purposes stated or reasonably implied at the time such personal information was provided to us).
Where your consent was required for our collection, use or disclosure of your personal information, you may, at any time, subject to legal or contractual restrictions and reasonable notice, withdraw your consent. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.
How is Your Personal Information Protected?
Nutrien endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to protect your personal information from loss and unauthorized access, copying, use, modification or disclosure.
Despite these safeguards, no method of transmission over the Internet or data storage is fully secure. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
How Long is Your Personal Information Retained?
Except as otherwise permitted or required by applicable law or regulatory requirements, Nutrien endeavors to retain your personal information only for as long as it believes is necessary to fulfill the purposes for which the personal information was collected (including, for the purpose of meeting any legal, accounting or other reporting requirements or obligations). We may, instead of destroying or erasing your personal information, make it anonymous such that it cannot be associated with or tracked back to you.
Updating Your Personal Information
It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of your employment, please keep us informed of such changes.
In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.
Access to Your Personal Information and Deletion of Your Personal Information
You can request access to, and rectification or deletion of personal information that we hold about you. Note that California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing. For additional information, that may apply based on your location, please see the State Specific Addenda below.
To make such a request, please contact the office of our Privacy Officer using the contact information set out below. Please note that any such communication must be in writing. In your request, please make clear what specific personal information you would like to have accessed, rectified, or deleted.
When requesting access to, or rectification or deletion of your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, rectify or delete, as well as to search for and provide you with the personal information that we hold about you. If you require assistance in preparing your request, please contact the office of our Privacy Officer.
Your right to access, rectify, or delete the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse your request. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.
In the event that we cannot provide you with access to, or rectification or deletion of your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.
Inquiries or Concerns?
January 1, 2020
State Specific Addenda
California Information Sharing Disclosure
California Civil Code Sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether the following categories of personal information are collected, transferred for “valuable consideration,” or transferred for an organization’s “business purpose” (as those terms are defined under California law). The table below indicates the categories of personal information we collect and transfer in a variety of contexts. Please note that because this list is comprehensive, it may refer to types of information that we collect and share about people other than yourself. For example, while we collect the bank account information of our current employees, we do not collect the bank account information of applicants that have not yet been hired.
|Category of Personal Information||Is information collected by us?||Is information transferred for valuable consideration?||Is information transferred for business purposes?|
|Audio, electronic, visual, thermal, olfactory, or similar information||✓||✓|
|Bank account number||✓||✓|
|Characteristics of protected classifications (e.g., age, sex, race, ethnicity, physical or mental handicap, etc.)||✓||✓|
|Driver’s License Number / State ID||✓||✓|
Health insurance information
|Identifiers (e.g., name or alias)||✓||✓|
Insurance Policy Number
|Other financial information||✓||✓|
|Social Security Number||✓||✓|