This Policy explains how Gap Inc. (“Gap” or the “Company”) collects, generates, uses, and discloses Personal Information (as defined below) about our employees residing in the US and its territories.
Please note that this Privacy Policy does not apply to medical, and health related information collected by The Gap Inc. health insurance plans. To learn more about how this type of information is handled, please refer to the HIPAA privacy information on the benefits site here or contact your benefits representative.
I. Personal information we collect
In this Privacy Policy, personal information means information related to an identified or identifiable employee, or as otherwise defined under applicable law. Personal information related to an employee typically consists of information collected solely within the context of our employment relationship.
For information on how we process personal information about our consumers, please refer to The Gap, Inc. Privacy Policy located at the bottom of our websites and within our mobile apps.
The types of personal information we may collect include:
- Personal details: first name and surname, gender, home address, telephone numbers, personal email address, date and place of birth, Social Security Number (“SSN”), marital status, dependents, emergency contact information, details and documentation required under immigration laws (such as citizenship, birth certificate, residency, or work permit);
- Health information: including but not limited to: COVID-19 vaccination-related information, your body temperature, COVID-19 related testing results, whether you have or display certain COVID-19 related symptoms, whether you have been in close contact in the last 14 days with anyone who has exhibited any COVID-19 symptoms or who has tested positive for COVID-19, any COVID-19 related doctor’s notes for absences or work restrictions, medical leave of absence records, requests for accommodation, interactive process records, and correspondence with you and your healthcare provider(s) regarding any request for accommodation or medical leave of absence related to an infectious disease;
- Picture and video data: Store, facility, and office locations may be monitored with CCTV systems or other devices, which may collect audio, photographic or video data depicting our employees and customers;
- Professional qualifications and interests: Details contained in letters of application, résumé/CV, and information given through online applications, previous employment background, references, education history, professional qualifications, trainings, continuing education, certifications, and other information submitted to us during the employment application process, which may be subject to the applicant privacy policy provided at the time the application is submitted;
- Compensation and payroll data: Base salary or wage, bonus eligibility, benefits, pay enhancements, pension contributions, details on stock options, stock grants, and other awards, salary reviews and performance appraisals, personal banking information, working time records (including vacation/holiday schedule, sick time or other absences, hours worked, flexible and home working hours, department standard hours and details of corporate travel), corporate credit card information, business expense reimbursement information, employee use of discount card/purchase history, and information required for statutory deductions and administration;
- Personnel data: Information related to appraisals, promotions, disciplinary actions, internal investigations, dates of absence and reasons for absence, driving license details, and details of any work accidents;
- Information regarding your potential and aspirations to consider your next steps in the organization;
- Information that an employee volunteers to include in a profile in electronic systems, including but not limited to a nickname, photograph, and interests;
- Other information: As permitted and allowed by applicable law, such as data that identifies health-related conditions to provide accommodations, sex, gender identity, sexual orientation and racial ethnic or national origin for diversity purposes, the commission or alleged commission of any offenses, and credit information.
II. Sources of personal information we collect
We collect personal information directly from you when you provide it to us, or when you access and use Company systems and property, as well as from other sources such as:
- Colleagues
- Managers
- References & personal acquaintance information you provide
- Prior employers or education providers
- Clients
- Background check providers
- Recruiters
- Employment networking and search companies and websites
- Security systems used to protect physical and IT assets
III. Electronic monitoring
Electronic monitoring includes all forms of monitoring that is done electronically. Why and how monitoring takes place depends on what is established for an employee’s roles and responsibilities.
Here are the reasons why and ways employees may be monitored. These are in addition to those set forth in Gap Inc’s Electronic Communication & Social Media Policy.
Why we may monitor:
- For the safety and security of our employees and others, the protection of our premises and in the event of an investigation;
- For the purpose theft, fraud, loss prevention and to prevent illegal behavior;
- To ensure employees adhere to workplace policies, to protect legal rights, equipment, systems, and data, especially those related to the use of IT systems;
- To manage and assess performance, productivity, and related incentive programs, ensure accurate compensation, and/or adherence to working time.
How we may monitor:
- By reviewing, logging, accessing, and searching the contents of an employee’s professional and permitted personal devices on Gap’s systems, including telephone, email, internet (e.g., browsing history and social media networking);
- By maintaining an archive of employee activities in their use of Gap owned electronic or personal devices on Gap’s systems such as email history, chat logs, phone calls, electronic work product, and text messages;
- By recording internet activities on Gap’s systems (even failed attempts to access sites);
- Through the use of video technology (e.g., CCTV), of both internal (e.g., breakrooms) and external public spaces (e.g., parking lots);
- Through the use of wearable and/or handheld technology and personal tracking or motion software (e.g., bar code, magnetic stripe, RF-enabled ID badges, & ergonomics);
- By monitoring all in store and online transactions using exception-based reporting applications; and
- By monitoring the entry and exit of Gap premises via burglar alarm and access control systems.
The above-noted electronic monitoring may be performed at any time, without further notice, to determine compliance with this section or with any other relevant Gap policy, standard, or procedure. Any information collected by electronic monitoring may be used during employee reviews, for disciplinary purposes, or in connection with legal proceedings.
Should employees have any questions or concerns related to the ways or means of these electronic monitoring activities, they should contact their direct Supervisor for more information.
IV. How we use personal information
Gap collects, generates, uses, and discloses personal information for any of the following purposes:
- Managing Our Workforce: Managing work activities and personnel generally, including recruitment, appraisals, promotions and succession planning, rehiring, administering salary, and payment administration and reviews, wages and other awards, loans, stock grants and bonuses, employee recognition and rewards programs, performing background checks, managing disciplinary actions, terminations, providing employees with life and healthcare insurance, pensions and savings plans or other benefits, leave, managing sickness leave, promotions, transfers, secondments, honoring other contractual benefits including company car and car allowance provision, , employee discount cards, as well as determining eligibility for and providing training, recreational activities, reporting and carrying out workforce analysis, performing background checks, managing disciplinary actions, grievances and terminations, making business travel arrangements, managing business expenses and reimbursements, planning and monitoring of career development activities and skills, responding to employee questions or concerns and creating and maintaining one or more internal employee directories;
- Communications and Emergencies: Facilitating communication with employees at the workplace location, home and when employees are traveling, ensuring business continuity and crisis management, providing references, protecting the health and safety of employees and others, safeguarding and maintaining IT infrastructure, office equipment, facilities and other property, facilitating communication with you and your nominated contacts in an emergency, issuing building entry and identification passes;
- Business Operations: Operating and managing the Company’s business such as the IT and communications systems, including company-sponsored online social networking sites, videoconferencing, file sharing, centralized email servers, marketing products or services, tracking product and service development, improving our products and services, managing company assets, resource and asset allocation, strategic planning, project management, business continuity, compilation of audit trails and other reporting to promote proper business practices, maintaining records relating to business activities, budgeting, financial management and reporting, communications within and outside of the Company, managing acquisitions, mergers, reorganizations or disposals and integrations with purchaser;
- Workforce Analytics: We use workforce analytics to assist in planning succession and to ensure business continuity, to design employee retention programs and diversity initiatives, to offer training opportunities, to identify patterns in the use of technology systems, to protect information entrusted to us, as well as to protect Gap’s people and property;
- Compliance: Complying with the Company’s policies and procedures, terms of use, and applicable legal requirements, including income tax and insurance deductions, record keeping and reporting obligations, conducting audits, and applicable legal requirements, including responding to legitimate requests from government or other public authorities, responding to legal process such as subpoenas, pursuing legal rights and remedies, defending litigation and managing any internal complaints or claims arising out of or relating to employment with the Company, monitoring activities as permitted by local law and Company policies;
- Safe Environment: To honor our commitment to maintaining a safe environment, to determine who should be permitted to enter certain physical locations and to maintain the health and safety of all individuals who enter our facilities; and
- Legal Authority: As otherwise required or permitted by law.
V. Disclosure of personal information and recipients
We may disclose the types of personal information we collect to third parties for the purposes listed above. We also disclose personal information to third party service providers pursuant to agreements to perform various services and business activities on Gap’s behalf. We do not authorize any of these service providers to make any other use or disclosure of your personal information.
Personal information will not be disclosed to third parties for their marketing purposes unless you have agreed to it.
Categories of third parties we disclose personal information to include:
- Professional advisors: Accountants, auditors, lawyers, insurers, bankers, and other outside professional advisors in all of the countries in which we operate;
- Service providers: Companies that provide products and services to Gap such as payroll, pension scheme, benefits providers or administrators; human resources services (such as companies that verify employees’ employment and education background and other information provided by the employee to us or that that conduct employee security checks and clearances), relocation and travel arrangement companies, performance management, training, expense management, IT systems suppliers and support; workers’ compensation boards and related bodies, third parties assisting with equity compensation programs, banks and credit card companies, medical or health practitioners, trade bodies and associations, landlords, security companies and access card providers, conference or training organizers or providers, schools, corporate survey administrators, and other service providers;
- Public and governmental authorities: Entities that regulate or have jurisdiction over Gap such as regulatory authorities, law enforcement, public bodies, and judicial bodies;
- Entities involved in a corporate transaction: A third party in connection with any proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Gap business, assets, or stock (including in connection with any bankruptcy or similar proceedings); and
- Business operations: Gap may also share an employee’s business contact information with customers, potential customers, vendors, and business partners to support regular business operations.
VI. Retention of personal information
Gap will retain records containing personal information in accordance with our Records Compliance Policy or as otherwise required by law.
VII. Information safeguards
We maintain technical and organizational security measures designed to protect your personal information consistent with industry standards.
VIII. Updating your personal information
Employees can use update features within the relevant HR applications (e.g., Workday); or if not available, contact your HR Generalist or the Employee Services at the Corporate Shared Services Center (“CSSC”) at (866) 411-2772.
IX. Additional information for California residents
If you are a California resident and an employee of Gap Inc., subject to legal limitations, you may have additional rights available to you regarding your personal information. You may request (i) to know the personal information we have collected about you, (ii) that we delete your personal information, and (iii) to have inaccurate personal information about you corrected.
The personal information we collect about employees is used solely within the context of our employer-employee relationship. We may not be able to fulfill a request, to the extent it restricts our ability to comply with applicable law, the terms of our employer-employee relationship, including the need to maintain and preserve records and information related to administer and provide health, professional, and other employment-related benefits. We do not use or disclose sensitive personal information unless it is necessary for the purposes of our employment relationship or is otherwise authorized by applicable law. We do not “sell” or “share” employee personal information, as those terms are defined under California privacy laws.
For more on how you can access and review certain employment-related personal information and who you can contact, or to make a request, please see the contacts in the “Contacts” section of this Policy.
X. Contacts
If you are an employee of Gap Inc., or one of Gap Inc.’s affiliates or subsidiaries, and have questions concerning your personal information or this Privacy Policy, feel that your confidentiality has been compromised, or observe behavior that is inconsistent with our Code of Business Conduct (“COBC”), the following resources are available:
- Use the Open-Door process and talk to your manager, next level manager, or HR;
- Contact your HR Generalist or the Employee Services at the Corporate Shared Services Center (“CSSC”) at 1-866-411-2772;
- Use the COBC Hotline: speakup.gapinc.com or 1-866-427-2633 (1-866-GAP INC.-CODE); or
- Contact Gap Inc.’s Privacy Team via email at: privacy@gap.com.
XI. Changes to This Policy
We may change this policy from time to time. You can tell if the policy has changed by checking the revision date that appears above. Any changes will become effective when we post the revised Policy on the Thread.
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