This Personnel Privacy Policy (“Policy”) describes the personal information that Oxford Industries, Inc., and our subsidiaries and affiliates including Tommy Bahama Group, Inc.; Tommy Bahama R&R Holdings, Inc.; Tommy Bahama Canada ULC; Sugartown Worldwide, LLC (d/b/a Lilly Pulitzer); Johnny Was, LLC; Southern Tide, LLC; The Beaufort Bonnet Company, LLC; and Duck Head, (collectively, “Oxford,” “we” and/or “our”) collect, use, disclose, transfer, and store (collectively, “process”) in connection with your employment or other professional engagement with Oxford. While this Policy is intended to describe the broadest range of our processing activities, these activities may be more limited in some jurisdictions based on local laws. For example, the laws of a particular state or country may limit the types of personal information we can collect or how we use that information. In those instances, we adjust our internal policies and practices to reflect the requirements of local law.

 

We may change this Policy from time to time. If we make changes to this Policy, we will notify you by revising the date at the top of this Policy. If we make material changes, we will provide you with additional notice, such as by sending you a notification.

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CONTENTS

 

1. Who Does This Policy Cover?

2. Applicability of Other Policies

3. Information We Collect

4. How We Collect Your Information

5. How We Use Your Information

6. How We Disclose Your Information

7. Applicants Residing Outside of the United States

8. Contacting Us

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Oxford Addendum for California Personnel

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​1. WHO DOES THIS POLICY COVER?

 

This Policy covers all directors, employees, contractors, consultants, and other individuals who currently work or previously have worked for Oxford (collectively, “Personnel,” “you,” or “your”) and any third parties whose information is provided to us in connection with any Personnel’s employment or engagement relationship with Oxford (e.g., emergency contact information).

 

Where we refer to “employment” or “engagement” in this Policy, we do so for convenience only, and this should in no way be interpreted as purporting to confer employment status on non-employees to whom this Policy also applies. This Policy does not form part of any contract of employment or engagement, does not confer any employment status or contractual right on any Personnel, and does not place any contractual obligation on us.

 

​2. APPLICABILITY OF OTHER POLICIES

 

This Policy does not cover our processing of personal information collected from you as a customer of one of our Oxford brands (including Tommy Bahama, Lilly Pulitzer, Johnny Was, Duck Head, Southern Tide, and The Beaufort Bonnet Company, each a “Brand” and collectively “Brands”) or visitor to one of our websites. To learn more about Oxford’s privacy practices in those cases, please see the relevant privacy policy on the particular Brand’s website. We also have a separate policy, our Applicant Privacy Policy, governing our data practices for job applicants, which is available here.

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In some cases, you may provide personal information to third parties that we work with, such as when you voluntarily sign up for certain services or benefits programs provided by third parties to our Personnel. By participating in such services or benefits programs, you understand that the information you provide to such third parties is not under our control and is not subject to this Policy. Please refer to the privacy policies of such third parties before providing them with your personal information.

 

3. INFORMATION WE COLLECT

 

We collect information in order to manage our relationship with you during the course of your employment or engagement with us. For example, we may collect:

• Identifiers, such as name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, phone number, social security number, driver’s license number, passport number, known traveler numbers, date of birth, and other similar identifiers;

• Eligibility to work information, such as citizenship, work permit, and visa application information;

• Financial information, such as banking and direct deposit forms, salary, tax forms, and expense reimbursement records;

• Information related to health insurance and other benefits, which relates to the application for, changes to, and enrollment in employee health and welfare benefits, life insurance, and retirement accounts, details on such benefits such as contribution and deferral levels, the names and other legally required information of beneficiaries, information about your spouse, partner, and dependents, and emergency contact information;

• Characteristics of protected classifications under state or federal law, such as age, gender, marital status, race, ethnicity, religion, sexual orientation, veteran status, and disability status;

• Professional and employment-related information, such as performance reviews and disciplinary reports; your applications, resumes, curriculum vitae, files you choose to share with us, cover letters, information provided to us during an interview, shared with us by references, or included in criminal background checks (where applicable), and our assessment of recruitment information; job title, picture, and employee number; employment history, current salary, and other work-related documentation including records, forms, logs, and agreements; and benefits elections;

• Education information, such as names, degree information, and graduation dates of educational institutions attended;

• Internet or electronic network activity information, such as browsing history, search history, information regarding your interaction with our websites, applications, and platform, and other information collected via cookies, web beacons and similar technologies;

• Geolocation data when you use certain Oxford-issued devices on Oxford properties, such as our retail stores or distribution centers;

• Information from publicly available sources, is collected in certain circumstances, such as information available from your social media pages, your LinkedIn profile, or personal website;

• Health and health-related information, such as information related to symptoms of, or risk of exposure to, certain illnesses (e.g., contact with others who may be sick or relevant travel history);

• Audio or visual information, such as headshots, clothing size, and information gathered via cameras and CCTV; and

• Employee-only social networking platform interactions, including, but not limited to, profile information, content submitted to the platform, and usage activity.

 

Monitoring: We reserve the right to monitor the use of our premises, equipment, devices, computers, network, applications, software, and similar assets and resources. In the event such monitoring occurs, it may result in the collection of personal information about you. Some Oxford facilities are equipped with surveillance equipment, such as cameras and CCTV, which may capture your image or information about your movements and which may be used to protect the safety of Oxford staff, visitors, and property, to monitor and troubleshoot issues with equipment or technology, or otherwise for any lawful purpose. In addition, any and all telephone conversations or transmissions, electronic mail or transmissions, or internet access or usage by Personnel by any electronic device or system, including but not limited to the use of a computer, telephone, wire, radio, or electromagnetic, photoelectronic, or photo-optical systems may be subject to monitoring at any and all times by any lawful means. This is not meant to suggest that all Personnel will in fact be monitored, but to alert you that, when using Oxford equipment and resources, you should not have any expectations of privacy with respect to your use of such equipment or resources. We will ensure that any personal information generated by this monitoring is treated in accordance with this Policy.

 

Sensitive Personal Information: In some cases, we may collect sensitive personal information about you, which requires a higher level of protection. Please note that, where permitted by law, we may collect, store, and use sensitive personal information about you, including race, ethnicity, sexual orientation, citizenship, and health and medical conditions. We collect this information for specific purposes, such as to accommodate a disability or illness, comply with legal obligations such as anti-discrimination or diversity regulations (where applicable), protect the health and safety of our employees, and facilitate internal programs relating to diversity, equity, inclusion, and anti-discrimination. We will use such sensitive personal information for the purposes set out in this Policy, or as otherwise described to you at the time such information is collected, and in accordance with applicable law.

 

4. HOW WE COLLECT YOUR INFORMATION

Most of the personal information we collect is obtained directly from you, such as when you applied to work for us, during the onboarding process and benefits enrollment, as part of health or safety screenings, and through participation in voluntary employee programs or platforms. We also collect personal information automatically, such as when monitoring the use of our premises, equipment, devices, computers, network, applications, software, or similar assets and resources. We may also receive information about you from other sources, such as from your previous employers or educational institutions, from other employees (e.g., performance reviews), third-party providers (e.g., benefit providers), your named references, medical professionals, legal bodies, and publicly available sources such as from your LinkedIn profile and other social media platforms.

 

5. HOW WE USE YOUR INFORMATION

 

We use your personal information for human resources and other business purposes, including establishing, managing, and terminating employment relationships, and for other business purposes, including managing our business, keeping our systems secure, and complying with specific legal obligations. Such uses include:

• To manage our employment and personnel, such as monitoring assignments, evaluating performance, making compensation determinations, training Personnel, communicating with you, responding to your requests, inquiries, and comments, carrying out disciplinary and grievance investigations, hearings, and appeals, making and recording disciplinary decisions, and considering those decisions in subsequent relevant employment and business decisions, evaluating applications for transfers to new positions within Oxford, verifying your information and completing reference checks, and determining the terms of a promotion;

• For operational purposes, such as distributing payroll and company benefits, updating Personnel files, conducting audits and training, reimbursing business expenses, providing IT support, facilitating participation in voluntary employee programs and platforms, and managing shifts, working hours, and attendance;

• For benefits administration purposes, such as administering and maintaining group health insurance benefits and additional wellness programs, retirement plans, life insurance, disability insurance, leave programs, and other Oxford-offered benefit programs;

• For marketing activities, such as using Personnel photos, videos, social media posts, and other content for internal and external marketing activities;

• For statistical and analytical purposes to understand and improve worker satisfaction, engagement, and performance;

• To administer our applications, software, and systems, including to ensure the security of our workforce, guests, property, and assets, and to monitor and audit network traffic and information in such applications, software, and systems;

• For legal and compliance purposes, such as to implement internal policies, detect, investigate, and respond to suspected fraud, security incidents, or other activity that is illegal or violates our policies, exercise a legal claim, cooperate with law enforcement investigations, and comply with applicable laws, regulations, legal processes, or governmental requests;

• To protect the health, safety, and vital interests of Oxford, Personnel, or of another natural person, such as during an emergency where the health or security of Personnel is in danger, to prevent physical harm or financial loss;

• To comply with our legal obligations and internal policies relating to diversity, inclusion, and anti-discrimination;

• As necessary and appropriate to provide reasonable accommodations;

• As necessary for the performance of a contract or in order to take steps at the request of our Personnel prior to entering into a contract (if you do not provide certain information when requested, we may not be able to perform the contract we entered into with you, such as paying you or providing a benefit); and

• To enable solely internal uses in a lawful manner that are reasonably aligned with your expectations based on our interactions with you and that are compatible with the context in which the information was provided to us.

 

6. HOW WE DISCLOSE YOUR INFORMATION

 

Within Oxford and among our corporate subsidiaries and affiliates: We may disclose your personal information to Oxford personnel and personnel who are employees of our subsidiary and affiliate Brands who need to know the information, including human resources, payroll, and information technology departments.

 

Service Providers and Contractors: We disclose personal information to service providers and contractors that need access to such information to perform services on our behalf. For example, we disclose certain information to service providers who assist with the administration of payroll, pension, benefits, performance management, training, communication platforms, and expense management, and facilitate internal programs relating to diversity, inclusion, and anti-discrimination.

 

Professional Advisors: We disclose information about you to our professional advisors, including accountants, auditors, lawyers, insurers, and bankers. We only permit these advisors to process your personal information for specified purposes and, as appropriate, in accordance with our instructions and the provisions of this Policy and applicable law.

 

Government Authorities, Regulators, and Similar Third Parties: We disclose personal information to courts, government authorities, independent external advisors, and internal compliance and investigation teams if we believe such disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process.

 

Other Third Parties: In certain limited circumstances, we disclose your personal information to other third parties, including (a) to comply with our obligations, to protect the rights and property of Oxford, our customers and the public, to cooperate with law enforcement investigations and to detect and respond to suspected illegal activity and threats to the health or safety of any person or of our systems or services, (b) in connection with, or during negotiations of, any merger, joint venture, sale of company assets, financing, or acquisition of all or a portion of our business, assets or stock by another company (including in connection with any bankruptcy or similar proceedings), and (c) with your consent and at your direction. In certain circumstances and only as necessary in connection with business operations, work contact details may be provided to customers, potential customers, and other third parties, where the disclosure is required by role.

 

We may also disclose aggregated or de-identified information, which cannot reasonably be used to identify you. Oxford processes, maintains, and uses this information only in a de-identified fashion and will not attempt to re-identify such information except as permitted by law.

 

7. PERSONNEL RESIDING OUTSIDE OF THE UNITED STATES

 

Additional Disclosures for Canada

If you reside in Canada, this section applies to you. You may exercise your rights to access and correct the personal information we hold about you by emailing us at hr@tommybahama.com. By submitting personal information to us or our service providers, you consent to the collection, use, disclosure, and transfer of your personal information in accordance with this Policy and as permitted or required by law. You may withdraw your consent at any time by emailing us at hr@tommybahama.com. If you withdraw your consent (or if you decide not to provide certain personal information), you acknowledge that we may not be able to provide certain benefits.

 

8. CONTACTING US

 

If you have any questions regarding this Policy, please call us at 1-888-725-1899 or contact us at humanresources@oxfordinc.com.

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