Workplace Privacy Notice
- Last Updated: November 18, 2025
Navy Federal Credit Union, together with its subsidiaries, affiliates and branches (collectively, “Navy Federal”, “we”, “us” or “our”), values your privacy and is committed to handling the information we have about you responsibly and in accordance with applicable law.
This Workplace Privacy Notice (“Notice”) applies to current or former employees or contractors of Navy Federal (“workforce members” or “you”). The Notice describes the types of information we collect about you in the context of your workplace relationship with us (“workplace information”), and how we collect, use, disclose and secure this information.
This Notice does not cover information we have about you as a user of Navy Federal’s products or services or otherwise apply outside the context of your workplace relationship with us. If you have obtained our products or services primarily for personal, family or household purposes, including as an applicant for credit, our Consumer Privacy Policy applies to the information we collect about you with respect to those products or services. This Notice supplements any other privacy policies or notices applicable to the Navy Federal services that you access or use, such as the Navy Federal Online Privacy Policy.
Your provision of some of the information described in this Notice is required, either to comply with applicable law or to accomplish the purposes described in this Notice; your provision of other information is voluntary. If you disclose any information relating to other people to us or our service providers in the context of your workplace relationship with us, you represent that you have authority to do so and to permit us to use the information in accordance with this Notice.
This Notice is not intended and shall not be read to create any express or implied promise or contract for employment, for any benefit, or for specific treatment in specific situations. Any limitations stated in this Notice regarding use or disclosure of your information generally do not apply to information that is publicly available or that is de-identified or aggregated subject to safeguards described below. To the extent this notice conflicts with other applicable laws, applicable law controls.
How We Collect Information About You
We collect workplace information about you from a variety of sources depending on your workplace relationship with us. For example, we, or others on our behalf, may collect this information:
- Directly from you or your agent or representative
- Indirectly from you, such as by observing your actions as a workforce member or drawing inferences from the information you provide to us directly or indirectly
as well as from:
- Our affiliates
- Our service providers, including to support human resource activities, employee benefits programs and workforce management activities
- Credit reporting agencies
- Other Navy Federal employees, as part of Navy Federal’s management, evaluation, training and discipline processes
- Our members and business customers, who may provide feedback on their interactions with you
- Public records or widely available sources, including the media and social networks and information that is made available by federal, state and local government entities
- Educational institutions and professional organizations
- Third parties you have authorized or directed to share information with us
- Monitoring technologies and access control systems, such as card swipes, key strokes, and video conference recordings and transcriptions, recruiters, job placement agencies, former employers, and other third parties in relation to processing your application to work at Navy Federal
- Any relevant third parties for a legal purpose, such as in response to a court order or to defend against a legal claim
- Any relevant third parties when necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party
- Sources disclosed in other applicable Navy Federal privacy policies, such as the Navy Federal Online Privacy Policy
We also create workplace information about you, such as records of your interactions with us, your Navy Federal employee identification number and email address, and details of your employment.
Types of Information We Collect About You
Depending on your workplace relationship with us, we, or a third party working on our behalf, may collect various types of workplace information about you. This information may include:
- Your identification and contact information, such as: given name; preferred name; previous name; nickname; gender; date and place of birth; honorifics and titles; physical address; mailing address; email address; telephone number; mobile number
- Your professional history and qualifications for work at Navy Federal, such as: details on past and present industry, roles, employer names and addresses, job titles/positions, business activities, and salary and benefits; academic information, such as schools attended and degrees obtained; professional licenses, certifications, memberships, and affiliations; professional skills (e.g., languages spoken) and other work-related qualifications and experience; data from LinkedIn profiles and similar professional platforms; information about role and compensation preferences, professional goals and interests, and work availability
- Your background check information, such as: reference information; professional background and education verification; criminal and credit history; other due diligence information
- Your government identification and other information on your eligibility for work at Navy Federal, such as: Social Security number; passport number; other government-issued identification number, such as tax identification number; driver’s license number; immigration or visa related numbers; citizenship; residency; nationality; country of birth; work authorization and immigration status; images of passports and signatures
- Financial information about you, such as: information on your Navy Federal salary and any Navy Federal bonuses, awards, or other financial incentives you receive; direct deposit information, such as bank account number and financial institution name and routing number; payroll deduction and withholding and other tax information; retirement account information; Navy Federal company credit card information, including information needed for issuance and transaction records; expense reimbursements information; independent contractor billing, insurance/bonding, and W-9 information
- Information on your family and friends, such as: names, date of birth and contact details of family members, emergency contacts, dependents and beneficiaries
- Information related to your Navy Federal benefits, such as: details of your Navy Federal benefits selections and documents to establish marital and dependent status
- Information on your health, such as: post-offer drug testing and other medical examination information and results; information related to your physical or emotional health, including any disabilities or limitations on performance of work duties or functions; workplace accident and illness information; health insurance information
- Electronic information about you, such as: IP addresses; cookies; online identifiers; unique device identifiers; geolocation data; logs and records regarding access and use of Navy Federal properties, devices, software, and networks, including badge in and out times, system log on and off times, browsing history, and any metadata generated
- Information to authenticate you when accessing our premises or systems, such as: digital signature; username and passwords; PINs; challenge/response questions and answers; facial and voice recognition data; fingerprints; other biometric data
- Your image and voice, such as: photographs; visual images; information collected by Navy Federal security systems, including video recordings; call center and video conference recordings; badge identifier photograph; personal appearance
- Information on your workforce activity at Navy Federal, such as: Navy Federal workforce status (full-time, part-time, or leave of absence); Navy Federal work schedule and job assignments; Navy Federal positions held, including pay band and title; Navy Federal work location, including in-office, remote, or hybrid status and physical and mailing work addresses; Navy Federal email address and phone number; Navy Federal performance, leave, attendance, disciplinary, and other records and reviews, including hours worked, meetings scheduled and attended, business travel details, accomplishments and awards, training and development information, complaint resolution information, discipline and counseling information, and job termination information; content you create as part of your Navy Federal work-related activities, including documents, reports, comments, and communications; recordings and transcriptions of meetings you attend
- Your views and opinions that you choose to publish, otherwise make public or share with us, including political views and religious and philosophical beliefs
- Other personal characteristics about you that you voluntarily share with us, such as regarding your race or ethnicity, nationality, religion, military/veteran status, disabilities or health conditions, language preferences, sexual orientation, gender identity/expression, trade union membership, family/household composition, lifestyle and social circumstances, and hobbies and interests
- Inferences about you drawn from the above categories to create a profile reflecting your abilities and aptitudes in the context of assessing your job performance and Navy Federal career opportunities
Why We Collect Information About You
Depending on your workplace relationship with us, we may collect workplace information about you for the following purposes, consistent with applicable law:
- Identity verification: verifying your identity
- Application processing: evaluating you for work at Navy Federal, including ensuring you are qualified and equipped for the role for which you are being considered and otherwise suitable for work at Navy Federal
- Background and reference checks: confirming and verifying your identity, education, work experience, and eligibility to work with us; checking references and criminal history; assessing creditworthiness; and conducting other financial due diligence
- Workforce performance and efficiency: developing, training, monitoring, evaluating and maintaining workforce performance and efficiency, including determining performance requirements, ensuring high standards of performance, and handling performance issues
- HR operations and services: administering our workplace relationship with you, including on-boarding and off-boarding; payroll and benefits administration; pension and retirement administration; managing vacation, sick, and other types of leave; and tax reporting
- Workplace commitments: fulfilling commitments to you described in your offer letter, workplace contract or benefits plan
- IT operations: managing and operating our IT and communications systems
- Business operations: maintaining and running a viable organization
- Financial management: managing and operating our financial affairs, including expenses and travel management
- Health, safety and security: ensuring the health and safety of our workforce, the physical security and safety of our premises, and the electronic security of our systems; providing workplace accommodations consistent with applicable law
- Investigations: detecting, preventing, investigating and addressing actual or potential fraud or other illegal activities, breaches of policy or violations of acceptable standards of conduct
- Legal compliance: complying with our obligations under applicable law
- Legal proceedings: establishing, exercising and defending our legal rights
- Other disclosed purposes: carrying out purposes described to you at the time the information is collected or in other applicable Navy Federal privacy policies, such as the Navy Federal Online Privacy Policy
To Whom Do We Disclose Your Information?
We disclose the workplace information we collect from and about you in a variety of contexts. For example, when permissible by law, we may disclose the covered information we have about you to:
- You
- Our affiliates
- Our business partners
- Our service providers who provide services on our behalf and help us run our business, subject to binding contractual obligations not to disclose or use the information other than to carry out the purposes for which we disclosed it
- Credit reporting agencies to report on your financial history and for other lawful purposes
- Clients, customers and counterparties of, or to, our organization as appropriate for your job (e.g., if you are a member-facing employee, we may share your name and business contact information with our members)
- Relevant government entities or any other relevant third party if we believe that disclosure of the information is necessary to:
- respond to the demands of an applicable subpoena, warrant, court order, summons or other legal process or in connection with a supervisory examination, civil investigative demand or other law enforcement inquiry or governmental request
- detect, prevent, investigate or address actual or potential fraud or other illegal activity
- establish, enforce or defend our legal rights, including to verify and enforce our terms and conditions and collect on past-due accounts
- protect the rights, property, safety or security of ourselves, our workforce, our customers or third parties
- otherwise comply with applicable law
- Any relevant third-party acquirer(s), in the event that we sell or transfer all or any relevant portion of our organization or assets (including in the event of a reorganization, dissolution or liquidation);
- Other third parties with your consent or at your direction, such as your family, your associates and your representatives
- Recipients disclosed in other applicable Navy Federal privacy policies, such as the Navy Federal Online Privacy Policy
In addition, consistent with applicable law, we may disclose to any relevant third party:
- Information that does not identify, relate to or describe you and that cannot reasonably be associated with or linked to you, including de-identified, aggregated and anonymous information
- Publicly available information
Where appropriate, we will limit sharing of your information in accordance with the choices you have provided us.
Do We Sell Your Information?
We do not sell your workplace information for monetary consideration.
How We Secure and Retain Your Information
Securing workplace information that we collect about you is one of our most important priorities. Consistent with our obligations under applicable law, we maintain physical, technical, electronic, procedural, and organizational safeguards and security measures that are designed to protect workplace information against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, or access, whether the information is maintained by us or by others on our behalf.
While we take caution and make reasonable efforts to protect workplace information when it is maintained by us or our service providers, no method of data storage is completely secure. In the event of a security incident that results in exposure of your workplace information, we will notify you in accordance with applicable law.
Changes to This Notice
We may change this Notice from time to time. Changes may be made for any number of reasons, including to reflect industry initiatives, changes in the law and changes to the scope of the Sites, among other reasons. When we make updates, we will let you know by appropriate means, such as by posting the revised Notice on this page with a new “Last Updated” date. Any changes to this Notice will become effective when posted unless otherwise stated.
How to Contact Us
For any questions, comments or complaints regarding our privacy practices, or if you need to access this Notice in an alternative format due to having a disability, please call us at 1-888-842-6328.
California Consumer Privacy Act Workplace Disclosure and Notice at Collection
This California Consumer Privacy Act Workplace Disclosure and Notice at Collection (“CCPA Workplace Disclosure”) applies solely to workforce members who are residents of California (“California workforce members”) and concerns our practices with respect to the personal information of California workforce members collected in the context of their workplace relationship with us (“covered personal information). It explains how we collect, use and disclose covered personal information subject to the California Consumer Privacy Act as amended by the California Privacy Rights Act (together “CCPA”). It also describes the privacy rights of California residents under the CCPA and how they can exercise those rights.
Under the CCPA, personal information means information that “identifies, relates to, describes or is reasonably capable of being associated with, or could reasonably be linked … with a particular [California resident] or household.” Personal information does not include publicly available information, lawfully obtained, truthful information that is a matter of public concern or information that is de-identified or aggregated.
Please note that the CCPA does not apply to certain personal information, such as information subject to the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, and certain other state or federal privacy laws. The CCPA therefore does not apply to information that we collect about California residents in connection with financial products or services that they apply for or attain from us for personal, family or household purposes. That information is subject to our Consumer Privacy Policy.
This CCPA Workplace Disclosure supplements any other privacy policies or notices applicable to California workforce members, such as the Workplace Privacy Notice, the Navy Federal Online Privacy Policy and the California Consumer Privacy Act Disclosure and Notice at Collection. Any terms in this CCPA Disclosure that are not otherwise defined have the same meaning as they do in the CCPA. This CCPA Workplace Disclosure also serves as our “Notice at Collection” under California law.
Types of Personal Information We Collect
In the past 12 months, we have collected the following categories of covered personal information about California workplace members:
- Personal identifiers, including those listed in other California statutes, such as: real name; alias; Social Security number; passport number; other government-issued number; Green Card number; driver’s license number; telephone number; email address; postal address; online identifier; account login credentials; device identifier; IP address
- Characteristics of protected classifications under California law, such as: date of birth/age; gender; military or veteran status; marital status; nationality; citizenship; request for family care leave; request for leave for employee’s own serious health condition; request for pregnancy leave
- Biometric information, such as: imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint or a voiceprint, can be extracted; keystroke patterns or rhythms; and gait patterns or rhythms
- Professional or employment-related information, such as title; salary; employment files; references
- Education information, such as details of your education and qualifications
- Financial information, such as: bank account numbers; debit/credit card numbers; cardholder or accountholder name and details; transaction details
- Commercial Information, such as bank account numbers; debit/credit card numbers
- Internet or other electronic network activity information, such as browsing history, search history or information regarding your interaction with an application website
- Geolocation data, such as any information used to identify your physical location
- Communications, recordings and images, such as audio, electronic, visual, views and opinions
- Inferences: Any derivation of information, data, assumptions or conclusions drawn from certain of the above categories used to create a profile reflecting the individual’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities and aptitudes
- Sensitive personal information under California law: includes certain government identifiers (such as a Social Security number, driver's license or passport number); an account log-in, financial account, debit or credit card number with any required security code, password, or credentials allowing access to an account; precise geolocation; contents of mail, email, and text messages; genetic data; biometric information processed to identify an individual; information concerning an individual’s health; sex life or sexual orientation; or information about racial or ethnic origin, religious or philosophical beliefs, or union membership
In the past 12 months, we have collected the following categories of sensitive personal information relating to California workforce members.
- Social Security number, driver’s license, state identification card or passport number
- Precise geolocation
- Racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs or union membership
- Mail, email and text message contents unless we are the intended recipient
- Genetic data
- Biometric information processed to identify that individual
- Health information
- Information concerning sex life or sexual orientation
- Information of California residents that we know are less than 16 years of age with parental consent
How We Collect Personal Information
In the past 12 months, we have collected the above-listed categories of covered personal information about California workforce members from the following categories of sources:
- Directly from you or your agent or representative
- Indirectly from you, such as by observing your actions as a workforce member or drawing inferences from the information you provide to us directly and indirectly
as well as from:
- Our affiliates
- Our service providers, including to support human resource activities, employee benefits programs and workforce management activities
- Credit reporting agencies
- Other Navy Federal employees, such as through Navy Federal’s management, evaluation, training and discipline processes
- Our members and business customers, who may provide feedback on their interactions with you
- Public records or widely available sources, including information from the media and social networks and information that is made available by federal, state and local government entities
- Educational institutions and professional organizations
- Third parties you have authorized or directed to share information with us
- Monitoring technologies and access control systems, such as card swipes, key strokes, and video conference recordings and transcriptions
- Recruiters, former employers, job placement agencies and other third parties in relation to processing your job application
- Any relevant third parties for a legal purpose (such as in response to a court order or to defend against a legal claim)
- Any relevant third parties when necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party
- Sources disclosed in other applicable Navy Federal privacy policies, such the Navy Federal California Consumer Privacy Act Disclosure and Notice at Collection
Why We Collect Personal Information
We collect and use the above-listed categories of covered personal information about California residents for the following purposes:
- Identity verification: verifying your identity
- Application processing: evaluating you for work at Navy Federal, including ensuring you are qualified and equipped for the role for which you are being considered and otherwise suitable for work at Navy Federal
- Background and reference checks: confirming and verifying your identity, education, work experience, and eligibility to work with us; checking references and criminal history; assessing creditworthiness; and conducting other financial due diligence
- Workforce performance and efficiency: developing, training, monitoring, evaluating and maintaining employee performance and efficiency, including determining performance requirements, ensuring high standards of performance and handling performance issues
- HR operations and services: administering our workplace relationship with you, including on-boarding and off-boarding; payroll and benefits administration; pension and retirement administration; managing vacation, sick, and other types of leave; and tax reporting
- Workplace commitments: fulfilling commitments to you described in your offer letter, workplace contract or benefits plan
- IT operations: managing and operating our IT and communications systems
- Business operations: maintaining and running a viable organization
- Financial management: managing and operating our financial affairs, including expenses and travel management
- Health, safety and security: ensuring the health and safety of our workforce, the physical security and safety of our premises and the electronic security of our systems; providing workplace accommodations consistent with applicable law
- Investigations: detecting, preventing, investigating, and addressing actual or potential fraud or other illegal activities, breaches of policy, or violations of acceptable standards of conduct
- Legal compliance: complying with our legal obligations under applicable law
- Legal proceedings: establishing, exercising and defending our legal rights
- Other disclosed purposes: carrying out purposes described to you at the time the information is collected or in other applicable Navy Federal privacy policies, such as the Navy Federal California Consumer Privacy Act Disclosure and Notice at Collection
We may also use personal information relating to California residents for one or more of the following business purposes listed in the CCPA:
- Auditing related to workforce members
- Detecting security incidents; protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity
- Debugging to identify and repair errors that impair existing intended functionality
- Short-term, transient use
- Performing services on behalf of Navy Federal or its service providers, including maintaining or servicing workforce members’ accounts, providing workforce members service, processing or fulfilling orders and transactions, verifying workforce members’ information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of Navy Federal or its service providers
- Undertaking internal research for technological development and demonstration
- Undertaking activities to verify or maintain the quality or safety of a service that is owned or controlled by Navy Federal, and to improve, upgrade or enhance the service that is owned or controlled by Navy Federal
Whether We Sell or Share Personal Information
We do not sell covered personal information to third parties, within the meaning of the CCPA (and have not done so in the last 12 months).
Other than as disclosed in our California Consumer Privacy Act Disclosure and Notice at Collection, we do not share covered personal information about California workforce members with third parties (and have not done so in the last 12 months).
To Whom We Disclose Personal Information
In the past 12 months, we have disclosed the above-listed categories of covered personal information about California workforce members to our service providers or contractors for all the above-stated purposes about why we collect information from California residents. Specifically: identity verification; application processing; background and reference checks; workforce performance and efficiency; HR operations and services; workplace commitments; IT operations, business operations and financial management; health, safety, and security; investigations; legal compliance; legal proceedings; and other disclosed purposes.
How We Retain Personal Information
We take reasonable steps designed to ensure that your covered personal information is only processed for the minimum period necessary for the purposes set out in this CCPA Workplace Disclosure. The criteria for determining the duration for which we will retain covered personal information about California workforce members are as follows:
1. We will retain copies of the covered personal information of California workforce members in a form that permits identification only for as long as:
a. We maintain an ongoing relationship with the California workforce members; or
b. The covered personal information is necessary in connection with purposes set out in this CCPA Workplace Disclosure
plus:
2. The duration of any applicable limitation period under applicable law; and where required by applicable law or a retention policy established in accordance with applicable law
In addition, if any relevant legal claims are anticipated/brought, we may continue to retain your covered personal information for such additional periods as are necessary in connection with that claim.
Once the periods above have concluded, each to the extent applicable or permitted by applicable law, we will 1) permanently delete or destroy the covered personal information, or 2) archive the covered personal information so that it is beyond use; or 3) anonymize the covered personal information.
Your Rights Under the CCPA
As a California workforce member, you may have one or more of the following rights under the CCPA:
- The right to know:
- the categories of personal information we have collected;
- the categories of sources used to collect the personal information;
- the business or commercial purposes for collecting your personal information;
- the categories of recipients with whom we share your personal information, including for cross-contextual behavioral advertising purposes; and
- the specific pieces of personal information we have collected about you
- The right to request, on legitimate grounds, deletion of your personal information that we collected;
- The right to opt out of our sharing your personal information for the purpose of cross-contextual behavioral advertising
- The right, in certain circumstances, to correct inaccurate personal information we collected about you
- The right not to be discriminated against for exercising any of these rights
How to Exercise Your CCPA Rights
If you are a California workplace member, you or your authorized agent can use any of the following methods to make a request to exercise the rights described above.
- Using the Public Portal
- Calling us toll-free at 1-888-842-6328
- Visiting one of our branches in California
Upon submission of your request, we will take steps to verify your identity, and if applicable, that of your authorized agent. Those steps may vary depending on your workplace relationship with Navy Federal and the intake method. Further, in rare cases, we may require you to visit a Navy Federal branch or acknowledge your identity before a notary public. If required for CCPA purposes, Navy Federal branches located in California (Branch Locator) that offer notary services will do so free of charge.
For agents submitting a request on behalf of another person, we may require proof of authorization. If you do not already have a valid power of attorney on file, you can designate an agent using our CCPA Power of Attorney Form. Parents/legal guardians making requests on behalf of their minor children will need to complete the Parent/Legal Guardian Cover Sheet and include a certified copy of the birth certificate or legal document to provide proof of their status.
Completed limited CCPA POA Forms and Parent/Legal Guardian Cover Sheets may either be:
- mailed to Navy Federal Credit Union, PO Box 2464, Merrifield, VA 22116-2464; or
- dropped off at a Navy Federal branch located in California (Branch Locator)
We will work to process all verified requests within 45 days. If we need an extension in order to process your request, we will reach out to you and provide you with an explanation for the delay.
In some instances, we may not be able to honor your request. For example, we will not honor your request if we cannot verify your identity or confirm that the personal information that we maintain relates to you or if we cannot verify that you have the authority to make a request on behalf of another individual. Additionally, we may not honor your request where an exception applies, such as where the disclosure of personal information would adversely affect the rights and freedoms of another individual or where the personal information that we maintain about you is not subject to the CCPA’s rights.
We will advise you in our response if we are not able to honor your request. We will not provide Social Security numbers, driver’s license numbers or government-issued identification numbers, financial account numbers, healthcare or medical identification numbers, account passwords or security questions and answers, or any specific pieces of information if the disclosure presents the possibility of unauthorized access that could result in identity theft or fraud or unreasonable risk to data or systems and network security.
Individuals Under 16 Years of Age
We do not have actual knowledge that we sell or share personal information of individuals under 16.
Aggregated and De-identified Information
For information about you that is de-identified or aggregated, we implement reasonable safeguards to prohibit re-identification or de-aggregation, as applicable. With respect to de-identified information, we commit to maintain and use the information in de-identified form and not to attempt to re-identify the information, other than for the sole purpose of determining whether the de-identification process satisfies requirements under California law.
Use and Disclosure of Sensitive Personal Information
We do not offer a right to limit our use and disclosure of sensitive personal information covered under this CCPA Workplace Disclosure because we do not use or disclose the covered sensitive personal information in such a manner as to require provision of the right (specifically, for purposes of inferring characteristics about an individual).
Changes to This CCPA Workplace Disclosure
We may change this CCPA Workplace Disclosure from time to time. Changes may be made for any number of reasons, including to reflect industry initiatives, changes in the law and changes to the scope of the Sites, among other reasons. When we make updates, we will let you know by appropriate means, such as by posting the revised CCPA Workplace Disclosure on this page with a new “Last Updated” date. Any changes to this CCPA Workplace Disclosure will become effective when posted unless otherwise stated.
How to Contact Us
- For any questions, comments or complaints regarding our privacy practices or if you need to access this CCPA Workplace Disclosure in an alternative format due to having a disability, please call us at 1-888-842-6328.