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Applicant Privacy Policy 2023

Last updated: October 10, 2023

This Applicant Privacy Policy (“Policy”) describes the policies we engage in regarding the collection, use, and disclosure of Personal Information about you – an applicant for employment, work opportunities, or independent contractor engagement with any entity comprising the Company (collectively, “Applicants,” “you” or “your”) – in connection with your candidacy for employment or independent contractor engagement, or otherwise for the purposes of work opportunities applications with us. The term “Masonite” refers to: Masonite International Corporation, a British Columbia corporation. The term “Masonite Group,” refers to, and consists of, for purposes of this Policy, the following Masonite corporate affiliates: Masonite Corporation, a Delaware corporation, Sierra Lumber, Inc., a Florida corporation, Endura Products, LLC, a North Carolina limited liability company, Masonite Distribution, LLC, a Delaware limited liability company, Sacopan Inc., a Quebec corporation, Premdor Crosby Limited, a private limited liability company established under the laws of England and Wales, any other Masonite subsidiary located in the United Kingdom, and Masonite Ireland, a private unlimited company established and resident under the laws of the Republic of Ireland. The terms “Company,” “we” or “us” refers to Masonite and the Masonite Group, collectively. Any capitalized terms not immediately defined are defined later in this Policy. The “controller” of your personal data is the relevant Company entity to which you have applied for employment, engagement, or work opportunities, which is set out in your application form or job posting/description, or terms of employment or work engagement (as applicable), and that Company entity is responsible for deciding how it processes and uses Personal Information about you. Speak to the Data Protection/Privacy Contact and Global Compliance Officer (see below) if you are unsure who the controller of your information is.

This Policy is available in French.

Cette Politique est disponible en francais à partir de la page 16.

 

1. Key Terms.

It would be helpful to start by explaining some key terms used in this policy:

  • California Resident: Resident of the State of California, located in the United States of America
  • Canadian Resident: Resident of Canada
  • Data controller: has the meaning given to it by the applicable data protection laws and where such term is not defined by the applicable data protection laws, it shall mean the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Information or Personal Data
  • Data Protection/Privacy Contact and Global Compliance Officer: Lauren Smith (lsmith@masonite.com)
  • European Resident: Resident of the Republic of Ireland, located in the European Economic Area, or any other country in the European Economic Area
  • Personal Information or Personal Data: Any information relating to an identified or identifiable individual
  • Special Category Personal Information: Personal Information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, Genetic and biometric data, Data concerning health, sex life or sexual orientation
  • Sensitive Personal Information: This includes Special Category Personal Information, as well as Personal Information that reveals social security, driver’s license, state identification card, or passport number; account log-in credentials; and precise geolocation information
  • UK Resident: Resident of a country in the United Kingdom of Great Britain

2. Personal Information We Collect About You and How we Collect It.

We may collect, store, and transmit your Personal Information in connection with your candidacy, including any Personal Information you provide to us during the application process, whether through an application or resume/CV you send to us, in person, or by telephone, text, or email. We may also collect information from other sources, including:

  • Directly from a third party, such as an outside recruiter
  • From a third party with your consent (e.g., background check provider where allowed by law)
  • Via our IT systems, including:
    • Door entry systems and reception logs
    • Monitoring of our technical systems, such as our CCTV and access control systems

Our Website Privacy Policy governs information collected when you visit one of our Company websites. For information about how we collect and use your information when you visit one of our Company websites, please refer to our Website Privacy Policy here, our CCPA Privacy Policy here if you are a California Resident, our Website Privacy Policy here if you are accessing from the UK or European Economic Area (“EEA”), and our Website Privacy Policy here if you are a Canadian Resident.

If you visit one of our facilities during the interview process and log in through the iLobby tool, any collection of data through iLobby is subject to the Notice at Collection provided at that time.

For Applicants that are California Residents, Personal Information does not include certain information that is exempted from the California Consumer Privacy Act (“CCPA”), and the California Privacy Rights Act (“CPRA”), such as information subject to the Fair Credit Reporting Act (FCRA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994, health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), nor does it include publicly available information from government records.

In particular, in the United States, and elsewhere only to the extent legally permitted, we collect and have collected the following categories of Personal Information from Applicants within the last twelve (12) months:

Category Examples Collected
 

 

 

A. Identifiers.

A real name, alias, maiden name, postal address, unique personal identifier, online identifier, social security number (or national equivalent), driver’s license number or state identification number and state of issuance, passport number, work and home email addresses.  

 

 

Yes

 

 

 

 

 

 

B. Personal Information categories

Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, address, address history, telephone number, Social Security Number or national equivalent, driver’s license or state identification card number and state of issuance, passport number, photograph, CCTV images at any Company location, date of birth, drug test results, background check results, education information, employment history, criminal history, information on your resume or CV. Some Personal Information included in this category may overlap with other categories.  

 

 

 

 

 

 

Yes

 

C. Sensitive personal information

Racial or ethnic origin, Social Security Number or national equivalent, driver’s license or government identification card number and state of issuance.  

 

Yes

 

D. Protected classification characteristics (as set forth under California or US federal

law).

Race, color, sex, gender, primary language, veteran or military status, reasonable accommodation information, legal right to work in country or employment authorization in country, as permitted/required.  

 

Yes

 

E. Professional or employment- related information.

Current or past job history or performance evaluations, information from reference checks, the existence of anything that may restrict your ability to work in the position for which you are applying such as a non-compete, confidentiality agreement, or license suspension, current or prior Board memberships, languages, skills, professional and work-related licenses, permits, certifications, Applicant personal website address.  

Yes

 

Category Examples Collected
 

 

F. Education Information

Education history, records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, dates of attendance, transcripts, confirmation of graduation, and class lists.  

 

Yes

 

G. Inferences drawn from other Personal Information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.  

 

Yes

We may also collect other Personal Information that you choose to provide to us.

In locations where permissible by law, we request that Applicants provide certain demographic information listed above on a voluntary basis (potentially including Sensitive Personal Information). Such information will be provided to an individual in the HR Department that is not responsible for making a hiring decision and/or will be anonymized. If you decline to provide requested demographic information, it will not be construed against your application.

If you have any questions about the Personal Information collection practices of a Company entity, contact the Data Protection/Privacy Contact and Global Compliance Officer.

3. How and Why We Use Your Personal Information.

Under certain data protection laws, including those applicable in the UK or EEA, we can only use your Personal Information if we have a proper for doing so, e.g.,:
  • To comply with our legal and regulatory obligations, including applicable immigration and/or employment laws and regulations where you are considered for employment;
  • For our legitimate interests or those of a third party, as summarized below (which are not overridden by your data protection interests or fundamental rights and freedoms, particularly taking into consideration the safeguards that we put in place);
  • Where you have given consent — which you may withdraw at any time;
  • To take steps prior to entering into an employment relationship with you, where you are considered for employment;
  • In circumstances where you have made the information public;
  • To protect the rights and interests of the Company, our employees, applicants, and others, as required and permitted by applicable

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

We generally will process Sensitive Personal Data that is subject to the GDPR or UK GDPR where we need to carry out our legal obligations or exercise rights in connection with your candidacy, where the processing is necessary for interview/candidacy adjustments or the assessment of your working capacity, or where it is needed public health or interests reasons; or in exceptional circumstances we may process this data with your explicit consent. Further, if we ask you to provide Personal Information (that is subject to the GDPR or UK GDPR) to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not (as well as of the possible consequences if you do not provide your Personal Information).

We only use Sensitive Personal Information that is subject to the CCPA for the following purposes:

(i) performing services reasonably expected by an average consumer; (ii) detecting security incidents; (iii) resisting malicious, deceptive, or illegal actions; (iv) ensuring the physical safety of individuals; (v) for short-term, transient use; (vi) performing or providing internal business services; (vii) verifying or maintaining the quality or safety of a service or device; or (viii) for purposes that do not infer characteristics about you.

The table below explains what we use (process) the Personal Information of Applicants, and, for our UK or EEA entities of the Company, our UK/EEA legal basis for doing so:

 

The purposes for which we use your Personal Information  

For UK or EEA Company entities: our legal basis for processing the Personal Information for this purpose

 

 

To process or evaluate your candidacy for employment or engagement.

To comply with our legal and regulatory obligations.

For our legitimate interests, i.e. to ensure Applicants are properly screened in an organised fashion.

 

To communicate with you regarding your candidacy.

For our legitimate interests or those of a third party, i.e., to ensure that your application experience proceeds in a professional and organised fashion.

 

The purposes for which we use your Personal Information  

For UK or EEA Company entities: our legal basis for processing the Personal Information for this purpose

For Applicants that are not applying for positions with our Company entities located in the UK or EEA: to conduct background checks as legally permitted.  

N/A

For Applicants that are not applying for positions with our Company entities located in the UK or EEA: to conduct drug tests as legally permitted.  

N/A

 

To conduct reference checks.

For our legitimate interests, i.e., to ensure that our Applicants are properly screened and qualified.
 

To verify professional qualifications.

For our legitimate interests, i.e., to ensure that our Applicants are properly screened and qualified.
To comply with professional, legal and regulatory obligations that apply to our business, such as record-keeping, equal employment opportunity laws, work permit and immigration regulations, reporting obligations, and the exercise or defense of legal claims.  

 

 

To comply with our legal and regulatory obligations.

Where and as permitted by law: to promote internal diversity, equity, and inclusion initiatives.  

N/A

Gathering and providing information required by or relating to audits, inquiries, or investigations by regulatory bodies.  

To comply with our legal and regulatory obligations.

 

Operational    reasons,    such    as    improving efficiency, training and quality control.

For our legitimate interests or those of a third party, i.e. to be as efficient, correct, and precise as we can.

 

The purposes for which we use your Personal Information  

For UK or EEA Company entities: our legal basis for processing the Personal Information for this purpose

 

Statistical analysis to help us manage, improve, and promote our business, e.g. in relation to our Applicant base and other metrics and enhancement or efficiency measures.

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can provide employment or engagement- related services to you.
Preventing unauthorized access to systems or our facilities. For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you.

To comply with our legal and regulatory obligations.

For Applicants that are residents of the United States and Canada: to market employment opportunities to Applicants.  

N/A

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided below.

We will only use your Personal Information for the purposes for which we collected it. If we need to use your Personal Information for an unrelated purpose, we will provide notice to you and, if required by law, seek your consent. We may use your Personal Information without your knowledge or consent where legally required or allowed. You will not be subject to hiring decisions based solely on automated data processing without your prior consent.

4. Job-Opening-Related Promotional Communications.

We may use the Personal Information of Applicants in the United States and Canada to send updates to them (by email or telephone) about employment opportunities with the Company.

We will always treat your Personal Information with the utmost respect and never sell it with other organizations outside the Company for marketing purposes.

Applicants in the United States have the right to opt out of receiving these employment-related promotional communications at any time by contacting us at recruiting@masonite.com. Applicants in Canada have the right to opt out of receiving these employment-related communications at any time by contacting us at recruiting@masonite.com.

We may ask you to confirm or update your promotional communications preferences if there are changes in the law, regulation, or the structure of our business.

5. To Whom We Disclose Your Personal Information.

We may disclose your Personal Information to:

  • Our affiliates, including companies within the Company, provided that, within the Company, only HR and management may have access to your Personal Information on a strictly need- to-know basis;
  • Service providers we engage to perform a service related to your candidacy, such as, where legally permitted, background check vendors and drug testing

We also impose contractual obligations on service providers to require that they only use your Personal Information to provide services to us and to you and that they take appropriate measures to protect your Personal Information.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some Personal Information with other parties, such as potential buyers of some or all of our business or during a re-structuring.

6. Personal Information Disclosed for a Business Purpose.

In the preceding twelve (12) months, the Company has disclosed Personal Information for a business purpose (see How and Why We Use Your Personal Information above) to the categories of third parties indicated in the chart below.

We do not “sell” or “share” Personal Information to third parties in exchange for monetary or other valuable consideration, nor do we share information with third parties for cross-context behavioral advertising.

Personal Information Category Category of Recipients
A: Identifiers service providers, affiliates
B: Personal Information categories service providers, affiliates
C: Sensitive Personal Information categories service providers, affiliates
D: Protected classification characteristics (under California or federal law) service providers, affiliates

 

Personal Information Category Category of Recipients
E. Professional or employment-related information service providers, affiliates
F. Non-public education information service providers, affiliates
G. Inferences drawn from other Personal Information service providers, affiliates

 

7. Where Your Personal Information is Held.

Information may be held at our offices and those of our Company entities, third party agencies, service providers, representatives, and agents as described above (see To Whom We Disclose Your Personal Information above).

Some of these third parties may be based outside of your country of origin. For more information, including on how we safeguard your Personal Information when this occurs, see below: “Transferring Your Personal Information”.

8. How Long Your Personal Information Will Be Kept.

We will keep your Personal Information while you are applying for a job or seeking an engagement or work opportunity with us, are employed or engaged with us if applicable, and as necessary to provide services to you. Thereafter, we will keep your Personal Information for as long as is necessary:

  • To respond to any questions, complaints or claims made by you or on your behalf;
  • To show that we treated you fairly; or
  • As required by law or

We will not retain your Personal Information for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of Personal Information. We will keep the demographic data we collect referenced in Paragraph 2 above only as long as needed for these purposes. We may maintain residual copies of your Personal Information and Sensitive Personal Information in our backup and archival systems for a limited period of time. For more information regarding our records retention, please contact us (see How To Contact Us below).

9. Keeping Your Personal Information Secure.

We have appropriate security measures in place designed to prevent Personal Information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your Personal Information to those who have a reasonable business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.

If you are a UK Resident and want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

10. Transferring Your Personal Information.

Personal Information Transfers from the EEA or the United Kingdom to the United States

It is sometimes necessary for us to share your Personal Information outside the EEA or the United Kingdom, as the case may be, in and to the United States of America, e.g.:

  • With our offices outside the EEA or UK;
  • With your and our service providers located outside the EEA and UK; or
  • If you are based outside the EEA or UK.

These transfers are subject to special rules under European and UK data protection law.

The United States of America does not have the same data protection laws as the United Kingdom and the EEA. We will, however, ensure the transfer complies with data protection law and all Personal Information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses click here for the EEA clauses or here for the UK clauses.

Additionally, Masonite is a member of, and complies with, the U.S. – E.U. Data Privacy Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information of Applicants transferred from both the European Economic Area and the United Kingdom to the United States of America. Contact privacy@masonite.com to obtain a copy of Masonite’s HR Data Privacy Framework Policy or visit https://www.dataprivacyframework.gov/ for more information.

Personal Information Transfers from Canada to the United States

If you are in Canada, we may transfer your Personal Information from Canada to the United States of America for the reasons listed above. The United States of America may not be deemed to provide the same level of privacy protection as Canada for the purposes set forth in this Policy. In the event of such a transfer, we ensure that the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses. For more information on the transfer safeguards we rely on and where they have been made available, or if you wish to access written information about our policies and practices regarding service providers outside of Canada, or if you have any questions about the Company’s practices regarding the use of service providers outside of Canada, please contact us (see How To Contact Us below). Additionally, for persons located in Canada: if your Personal Information is transferred to the

United States of America, it may be accessed by the courts, law enforcement, and national security authorities there.

11. Your Rights Under the GDPR and the UK GDPR.

Where the General Data Protection Act (GDPR) and the United Kingdom General Data Protection Act (UK GDPR) applies, they provide you with the following rights to exercise free of charge regarding your Personal Information:

Right to Access The right to be provided with a copy of your Personal Information.
Right to Rectification The right to require us to correct any mistakes in your Personal Information.
Right to be Forgotten The right to require us to delete your Personal Information—in certain situations.
Right to Restriction of Processing The right to require us to restrict processing of your Personal Information—in certain circumstances, e.g. if you contest the accuracy of the data.
Right to Data Portability The right to receive the Personal Information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
Right to Object The right to object: at any time to your Personal Information being processed for direct marketing (including profiling); and in certain other situations to our continued processing of your Personal Information, e.g. processing carried out for the purpose of our legitimate interests.
Right Not to be Subject to Automated Individual Decision-Making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

 

13. Your Rights Under the CCPA and CPRA.

The CCPA and CPRA provide California Resident Applicants with certain rights to exercise free of charge regarding their Personal Information:

 

Right to Know The right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive your request and confirm

 

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions.
 

Right to Correct

You have the right to request that that we correct inaccurate Personal Information that we have collected from you and retained, subject to certain exceptions.your identity (see How to Exercise Your Rights California Residents below), we will disclose to you:

· The categories of Personal Information we collected about you.

· The categories of sources for the Personal Information we collected about you.

· Our business or commercial purpose for collecting or selling that Personal Information.

· The categories of third parties with whom we share that Personal Information.

· Upon request, the specific pieces of Personal Information we collected about you.

 

Non-Discrimination We will not discriminate against you for exercising and of your rights under CCPA and CPRA.

 

14. Your Rights Under Canadian Data Privacy Laws.

If you are a Canadian Resident, it is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during the recruitment process. By law you have the right to request access to and to correct the Personal Information that we hold about you or withdraw your consent to the use of your Personal Information under certain circumstances. If you want to review, verify, correct, or withdraw consent to the use of your personal information, please contact us at as set forth in Paragraph

  1. Any such communication must be in writing.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the Personal Information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the Personal Information that we hold about you, or we may have destroyed, erased, or made your Personal Information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

15. How to Exercise Your Rights – California Residents.

If you are a California Resident and would like to exercise any of your rights as described in this Privacy Policy, please:

  • Call us, toll-free, at 866-996-2858;
  • Complete a request form on Frontdoor as available; or
  • Email us at caHRprivacyrequest@masonite.com If you choose to contact directly by email, you will need to provide us with:
    • Enough information to identify you (e.g., your full name, date of birth, home address, and telephone number);
    • A description of what right you want to exercise and the information to which your request

In order to process requests, we will need to obtain information to locate you in our records or verify your identity depending on the nature of the request. In most cases, we will collect some or all of the following data elements: first and last name, email address and/or home address, date of birth, and telephone number. In some cases, we may request different or additional information, including a signed declaration that you are who you say you are, and will inform you if we need such information.

Authorized agents may exercise rights on behalf of California residents by submitting a request via email or our phone number listed below and indicating that they are submitting the request as an agent. We will require the agent to demonstrate authority to act on behalf of the resident by providing signed permission from the resident. We may also require the resident to verify their own identity directly with us or to directly confirm with us that they provided the authorized agent permission to submit the request.

16. How to File a GDPR or UK GDPR Complaint.

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation and the UK General Data Protection Regulation, respectively, also give you right to lodge a complaint with a supervisory authority, in the European Union (or EEA) state or the United Kingdom (where you work, normally live, or where any alleged infringement of data protection laws occurred). The supervisory authority in the United Kingdom is the Information Commissioner’s Office (www.ico.org.uk), and the website for the Data Protection Commission in Ireland can be located here: ( https://www.dataprotection.ie/en/). Other supervisory authorities located in the EEA can be found here.

17.  Changes to This Privacy Policy.

We may change this Privacy Policy from time to time–when we do, we will endeavor to inform you via the “Career” tab on masonite.co.uk for the UK and EEA, www.masonite.com for the U.S., www.Masonite.ca for Canada, or other means of contact such as email. This Policy supersedes and replaces any prior Applicant Privacy Policy and supersedes any Website Privacy Policy to the extent the Website Privacy Policy refers to the data of Applicants (unless any such policy specifically states otherwise).

18. How to Contact Us.

Please contact us by post, email or telephone if you have any questions about this Applicant Privacy Policy or the information we hold about you. Our contact details are shown below:

Masonite International Corporation Attn: Global Compliance Officer 1242 E. 5th Avenue, Tampa FL 33605

caHRprivacyrequest@masonite.com for Applicants located in North America

privacy@masonite.com for Applicants located in Canada

UKEEAHRprivacyrequest@masonite.com for the UK and EEA Applicants

 866-996-2858 for California Resident Applicants

  1. Do You Need Extra Help?

If you would like this notice in another format (for example: audio, large print, braille) please contact us (see How to Contact Us above).

20.  Additional Information

Nothing contained in this Applicant Privacy Policy is intended to create a contract for employment or engagement, as the case may be, nor a promise to hire or engage.

For US Applicants: Masonite Corporation is committed to a diverse and inclusive workplace. Masonite Corporation is an equal opportunity employer and does not discriminate on the basis of race, color, ancestry, national origin, citizenship, gender, gender identity, sexual orientation, marital status, protected veteran status, disability, age, or other legally protected status. For individuals with disabilities who would like to request an accommodation, please contact recruiting@masonite.com.

For Canadian Residents, UK Residents, and European Residents: All applicable affiliates of the Company are committed to a diverse and inclusive workplace. All applicable affiliates of the Company are equal opportunity employers and do not unlawfully discriminate on the basis of race, color, place of origin, gender expression, gender identity, sexual orientation, disability or handicap, age, or other legally protected status in the relevant jurisdiction. If you are a UK or EEA Applicant and require an accommodation/reasonable adjustment, please contact

UKEEAHRprivacyrequest@masonite.com. If you are a Canadian Applicant and require an accommodation/reasonable adjustment, please contact privacy@masonite.com.