Olin California Consumer Privacy Act Disclosure for Olin Employees, Applicants, and Contractors

California Information on Processing of Personal Information
Olin Corporation, and its subsidiaries as listed with the SEC, (“Olin”) is committed to the responsible management, use, and protection of personal information. This document describes our practices in connection with the information that Olin collects from you in connection with your job application and/or employment with Olin. Note that some of the data collection and uses described below may not apply to you.

Data Protection Officer. Olin has appointed Megan Rosenberg, dpo@olincom.solidspace.com or +1.314.355.8285 as the Olin Global Data Protection Officer.

Your personal information may be processed for the purpose of:

  1. Human resources administration, including facilitation of applications and background checks, where appropriate, internal employee management, corporate travel and other reimbursable expenses, development and training, absence monitoring, timekeeping, performance appraisal, disciplinary and grievance processes, administration of termination of employment, reporting, career planning, talent management, relocation, learning management, promotion of Olin’s values, succession planning and other general administrative and human resource related processes;
  2. Payroll and benefits, including incentives and coordination of compensation, keeping beneficiary details;
  3. Recordkeeping, including accounting, commercial, procurement, document management and other similar services; reporting financial information and financial background checks, consultancy and advisory services, and corporate credit cards;
  4. Administrating external workforce and independent contractors, planning and allocation of resources;
  5. Production of products, integrated supply-chain, logistics, plant design, documentation tools, engineering drawings, enterprise resource planning and analytics, log book for facilities, task list for operators, event and associated action items, handling of maintenance, requisitions workflow, product quality, plant visitor administration, development of products, technologies and services, research;
  6. With respect to promoting Olin products or Olin as a company, engaging in advertising, marketing, public relations, reputation, branding, and event organization;
    Administrating and enhancing customer relationships, customer data trending and analysis;
  7. Environmental, health and safety, including security of the working environment, maintenance of medical and sickness records and occupational health programs, keeping emergency contacts, environmental protection and sustainability management, labor tracking for billing, behavioral safety, statutory reporting obligations;
  8. IT services, providing the IT infrastructure including hardware and software, enabling telecoms and electronic communications and organization, including the Internet, mobile applications, remote access, online meetings, collaboration tools and other resources, storage for electronic records, license allocation, allocation of user rights, debugging and troubleshooting, firewall and intrusion prevention, URL and malware filtering and reporting, tracking of files copied to removable media, ticket systems for requests;
  9. IT security management, monitoring and forensic tasks to protect the safety and security of employees, customers and property, including controlling and facilitating access to and monitoring activity in secured premises and activity using computers; and
  10. Corporate policy, corporate compliance, regulatory, export compliance and legal subject matter training; fulfillment of legal tasks including investigating and responding to claims against the company and its customers and employees, handling complaints, electronic signatures, internal audits, third party due diligence systems, including anticorruption screening, operation of whistle blowing hotlines, and other such purposes in relation to the above-mentioned services.

We have received your personal information mainly because you provided it to us or we have been collecting it during the course of the employment relationship. We may receive a limited portion of personal information from third parties, such as prior employers, education institutions you attended, your references, or service providers who are conducting background investigations for us, including checking references, medical evaluations, or financial records among other things.

Your personal information will only be accessible to respective employees of Olin, and its subsidiaries who, within their job responsibility, execute the purposes listed previously. Furthermore, external service providers and other third parties who are engaged to assist with the execution of the tasks describe in the ‘Purposes of processing’ section may have access to your personal information, for example IT maintenance service providers or benefits providers. Finally, as noted above, we may share your personal information as required to comply with legal or regulatory obligations. We do not sell your personal information.

We may be processing the following categories of personal information. Please note that we do not necessarily process all of such information about you. For example, we will be processing information about children only to the extent it is required in connection with Olin employment. This might be the case for tax calculation purposes, if your child is participating in an Olin contest, or we are providing relocation services to you. We restrict the processing of your personal information to the minimum amount required to accomplish the purpose for which it was collected.

A. Personal Characteristics, such as:

  • First Name/Initial
  • Middle Name/Initial
  • Last Name
  • Age
  • Date of Birth (Full or M/Y)
  • Social Security Number
  • Gender
  • Birth Certificate Number
  • Height
  • Marital Status
  • Nationality
  • Leisure and Interests
  • Photographs
  • Information about relatives
  • Membership in charitable, union or voluntary organizations
  • Member of a church
  • Number of Children
  • Name of Child
  • Age or Gender of Child
  • Other information in relation to a Child

B. Business Contact Information, such as:

  • Employing company
  • Position/Job Title
  • Initials Only
  • Business Address
  • Business Phone
  • Business Email Address
  • Mobile Phone Number

C. Private/Personal Directory Information, such as:

  • Home Postal Address
  • Home Telephone Number
  • Home Facsimile Number
  • Personal Email Address
  • Personal Cellular, Mobile, or Wireless Number
  • Social Media Handle
  • Instant Messenger Screen Name
  • Friends’, family members’ or relatives’ email address

D. Employment Details, such as:

  • Employing company
  • Work location
  • Job description
  • Start date/years of service with the company
  • Previous positions in the company
  • Career history
  • Recruitment details (e.g. date)
  • Termination details (e.g. date)
  • Attendance records
  • Accidents records
  • Performance appraisals
  • Security records (Background)
  • Salary
  • Payments
  • Loans
  • Benefits
  • Grants (e.g. gifts or donations)
  • Insurance details
  • Pension information
  • Relocation-related information
  • Travel preferences
  • Other employment-related data

E. Education and Training Information, such as:

  • Degrees or Schooling
  • Licenses and Professional Membership
  • Academic Record
  • Qualifications
  • Skills
  • Training Records
  • Professional Expertise

F. Health Information, such as:

  • Disabilities
  • Medical Record Number
  • Medical Diagnosis
  • Medical History
  • Information related to Medical Payment
  • Health Insurance name/identification or ac-count number
  • Drugs, Therapies, or Medical Products or Equipment Used
  • Work accidents and injuries
  • Medical exposure data/industrial hygiene

G. Financial Related Information, such as:

  • Expenses
  • Bank Account Number
  • Income tax relevant information
  • Financial Transactions History
  • Credit History or Credit Check
  • Insurance Claim History
  • Customer Purchase History (e.g. products, rentals, returns)
  • Household Income Data
  • Credit/Debit Card Number
  • Cardholder Name
  • Expiration Date
  • CVV, CVC2, CID Number (Code Verification Value Code)
  • PIN Data

H. Government Used Identification Numbers, such as:

  • Federal Issued Identifier
  • National Identity Card
  • National/State/Region Issued ID Number
  • Driver’s or Operator’s License Number
  • Government Identifiers for Professionals
  • Passport Number
  • Alien Registration Number
  • Digital Signature

I. Other Sensitive Personal Information, such as:

  • Any required credentials, usernames, Security Code, Access Code, or Passwords
  • Criminal Convictions

J. Mobile Device Information, such as:

  • Identification derived from a unique identifier (e.g. from name, MSISDN, IMSI, IMEI, IC-CID
  • Mobile Device Location (current)
  • Mobile Device Location (past)
  • IP address
  • Mobile Device Content (i.e. audio, video, calendar, contracts, messages)

K. Analytics Information, such as:

  • Device type and attributes
  • Computing system attributes, including without limitation, operating system attributes; and application attributes
  • IP address
  • Cookie and similar IDs
  • Geo-location information
  • Profiles

L. Children’s Information Collected Directly from Child, such as:

  • Name of Child
  • Age or Gender of Child
  • Address of Child
  • Child’s Location Information

The purposes of use are numbered above as 1 to 11. The types of data are lettered A to L. The below matrix shows which types of data are used for which purpose:

Purpose Types of Data
1 A, B, C, D, E, F, G, H, I, J, K, L
2 A, B, C, D, F, G, H, I, L
3 A, B, C, D, E, F, G, H, I, J, K, L
4 A, B, D, E
5 A, B, D, E, G
6 A, B, D, L
7 A, B, D
8 A, B, C, D, F, H, I, J, K
9 A, B, C, D, E, F, G, H, I, J, K, L
10 A, B, C, D, E, I, J, K
11 A, B, C, D, E, F, G, H, I, J, K, L
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