Better Employee, Contractor, Applicant Data Collection Notice
As described in this Notice of Data Collection (“Notice”), Better Holdco, Inc., Better Mortgage Corporation and their affiliates and subsidiaries (collectively, “Better,” “we,” “us”) collect and use certain personal information relating to our current, former full-time, part-time, prospective and temporary employees and staff, as well as our officers, directors and owners (each an “Employee”).
This Notice applies to personal information that we collect and use in order to start/manage the employment relationship and administer benefits to Employees. This includes information submitted by you or on your behalf by a third-party.
This Notice explains what personal information we collect about Employees, including when you apply for full-time or part-time employment at Better; seek contractor/contingent, consultant or other positions at Better; receive an offer of employment or a work or services agreement from Better; accept an offer of employment or enter into a work or services agreement with Better; or work at Better as an employee or contractor.
This Notice also explains the purposes for which we collect personal information from Employees. Certain rights, requirements, and disclosures in this Notice may be subject to exemption or otherwise may not apply based, for example, on applicable law or regulations. We may provide Employees additional notices about our data collection practices that are covered by specific legal requirements (e.g., if we conduct a background check and/or collect health information).
Categories of Personal Information Collected
Better collects personal information from you during the application process and throughout
the scope of your employment with Better. The categories of personal information collected may include the following:
Name, Contact Info, and other Identifiers. Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, immigration status, driver’s license number, passport number, or other similar identifiers.
Employment Details. Information such as job title/position, office location, hire dates, employment contracts, including confidentiality agreements and proprietary rights agreements and restrictive covenant agreements, performance and disciplinary reviews and records, grievance procedures, sickness/holiday records, assigned tasks and projects, weekly hours, supervisor’s name, start and end date, and reason for leaving employment.
Educational and Professional Background. Details such as academic/professional qualifications, education, CV/resumé, reference letters, interview notes and evaluations; criminal records data and credit information (for vetting purposes, where permissible and in accordance with applicable law); photographic images; skills, talents, career goals, aptitude, reviews, employee ratings, terminations; hours worked, employee policy acknowledgments, position profile data, vacancies, job descriptions.
Spouse, Beneficiary and Dependent Information; Marital Status; Other Family Information. Including information relating to emergency contacts and beneficiaries and dependents under Company benefits.
Financial Information. Information such as banking details, tax information, payroll information, withholdings, salary, benefits, bonus and commission entitlements, expenses, company allowances, stock and other equity grants.
IT Information, Electronic Systems and Office Access. Information required to provide access to and monitor use of Better’s electronic systems and networks such as browsing history, search history, e-mails, videos, photographs, instant-messenger data and documents and information regarding interaction with an internet website, application, or advertisement, as well as physical and network access logs and credentials and other network activity information related to use of a company device, network or other information resource. Includes time and geolocation data related to use of an internet website and applications. Also includes information to monitor access and location at a Better office.
Protected Classifications. Characteristics of protected classifications under state or federal law such as racial or ethnic origin, sex, disability information, and other characteristics protected by law.
Health and Medical Information. As required by law or as necessary to manage the employment agreement and workplace, including benefits administration, occupational health, disability accommodation, health status while in the office, workers’ compensation, and leaves of absence. In addition, to ensure a safe and healthy workplace for all employees and visitors.
Travel Information. Information relating to travel for company business or otherwise relating to travel before entering a Better location.
Profiles and Inferences. Inferences drawn from any of the information identified above to create a profile about an Employee reflecting the Employee’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Other. Other information you choose to share with us – e.g. hobbies, leisure activities, affiliations, social preferences, etc.
Purposes for Collecting and Using Personal Information
Better may collect the personal information identified above for a number of business purposes, including:
To Recruit and Inform Employees. Including to conduct employment related background screening and checks and to contact you and to inform you about benefits or information relating to your employment or potential employment.
To Administer Benefits. To administer benefits, such as medical, dental, optical, commuter and retirement benefits, including recording and processing eligibility of dependents, absence and leave monitoring, insurance and accident management and provision of reward information and statements.
To Pay and Reimburse for Expenses. Including salary administration, payroll management, payment of expenses, to administer other compensation related payments and administration of equity compensation plans.
To Conduct Performance-Related Reviews. Including performance appraisals, career planning, skills monitoring, job moves, promotions, and staff reorganizations.
To Review Working Hours and other Requirements. Including reviewing reported time worked and monitoring and managing PTO, holiday, FMLA, and other leaves of absences.
To Monitor Work-Related Licenses and Credentials. Including provisioning software licenses for use during an Employee’s work-related responsibilities; ensuring licensing, compliance, training, examination and other requirements are met with applicable regulatory bodies and licensing authorities.
To Generally Manage the Employment Relationship. Including administering and monitoring compliance with our policies and procedures, administering or performing employment contracts, where applicable, and for professional development and training purposes.
To Administer Location Changes. Including relocation services, work-from-home practices, documenting location assignment terms and conditions, obtaining relevant documents and initiating vendor services, including with respect to international assignments.
To Maintain Your Contact Information. Including altering your details across relevant entities within our company (for example personal, other employment and transferring roles), for contact information in case of a personal or business emergency, and for facilitating Employee communication and collaboration, such as through corporate directories, company profiles and through employee bios.
To Monitor Eligibility to Work in the United States. Monitoring and ensuring compliance of employees’ ability to work in the United States and local jurisdictions.
To Facilitate Our Working Environment. Includes conducting staff surveys, providing management with information about employees, and conducting training.
To Ensure a Safe, Healthy and Efficient Working Environment. Including by taking actions relating to disciplinary actions, and code of conduct processes and investigations and to provide you with support and to respond to your inquiries, including to investigate and address your concerns, and monitor and improve our responses. Also to reduce the risk of spread of any communicable disease, to protect employees and visitors from exposure to health or safety threats, to collect information regarding potential health and safety threats, and to comply with applicable law and regulation.
To Maintain and Monitor IT Systems and Electronic Resources. Includes hosting and maintenance of computer systems and infrastructure; management of Better’s software and hardware computer assets; systems testing, such as development of new systems and end-user testing of computer systems; training; and monitoring email and Internet access.
To Provide for Auditing, Accounting and Corporate Governance. Including relating to financial, tax and accounting audits, and audits and assessments of our business operations, security controls, financial controls, or compliance with legal obligations, and for other internal business purposes such as administration of our records retention program.
To Support Strategic Business Transactions. Including for purposes of planning, due diligence and implementation of commercial transactions (e.g., mergers, acquisitions, asset sales or transfers, strategic partnerships, reorganizations or other similar business transactions).
To Comply with Applicable Law or Regulatory Requirements. Such as legal (federal, state and local) and internal company reporting obligations, including headcount, management information, demographic and health, safety, security and environmental reporting.
Recipients of Personal Information. Better may disclose Employee personal information to a third party for a business purpose, including to our service providers. We may share personal information with the following categories of third parties:
- Service providers, including with respect to payroll, benefits providers, applicant tracking services, and others.
- Third parties with whom you direct us to share your personal information.
- Other third parties such as consumer reporting agencies, including GoodHire, when we perform Employee background screenings, or federal and state licensing authorities for licensed employees, when required.
- In response to lawful requests by public authorities.
If you have any questions regarding our use of personal information as described in this Notice, please contact the Better People Operations Team or email@example.com.
Changes to this Notice
We reserve the right to update this Notice at any time to reflect changes in our business, legal or regulatory obligations. Any changes to this Notice will be effective from the date they are provided to you.
Effective Date: January 1, 2020
Last Updated: June 30, 2020