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  • Last Updated: January 27, 2023
  • Effective Date: January 1, 2023

Navy Federal Credit Union, together with its subsidiaries, affiliates, and branches (collectively, “Navy Federal”, “we”, “us” or “our”), knows the privacy and security of your Personal Information is important to you. We are committed to the proper handling of the Personal Information (as defined below) collected or processed in connection with your employment relationship with us. This  Workplace Privacy Notice describes how we collect and use Personal Information about you. We may update this Notice from time to time.

How We Collect Your Personal Information

We collect Personal Information about you through the application and recruitment process, directly from you or from other employees, employment agencies, screening services, or other background-check providers. We may collect additional information from third parties, including former employers, credit reference agencies, or other sources that supply employment verification services.

Information We Collect About You

“Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual or a household. The following lists describe Personal Information that we may collect about you, depending on the workplace relationship we have with you. We may use any and all of the information described below for any of the purposes described in this Workplace Privacy Notice or for our business, security, or operational purposes compatible with the context in which the Personal Information was collected, unless limitations are listed in this Workplace Privacy Notice or described elsewhere at the time of collection of the information.

A. Employees, Emergency Contacts and Beneficiaries 

We may collect the following categories of Personal Information from you if you become an  employee of Navy Federal. 

Categories of Employee Personal Information Collected
Context of Collection of Personal InformationTypes of Personal Information CollectedPrimary Purpose for Collection and Use of Personal Information
New Hire Onboarding InformationWe may collect your name and contact information, job title, duties, driver’s license number, passport and other government identification numbers, date of birth, and immigration and work authorization status. We may also collect employee photos for identification badges and system profiles, other biometric information, emergency contact information and in some cases,  post-offer medical examination information and results, including drug test results.We use this information to maintain adequate human resources records, provide you with facility access needed to complete your job duties (in certain jurisdictions), verify eligibility, and process your initial employee benefits information. In some cases, we are required by law to collect this information.
Pay InformationWe may collect pay rate/salary information, payroll deduction information, withholding tax information, banking information for direct deposit, and information required to issue a business credit card and/or for expense reimbursement.We use this information to ensure that you are paid, to provide you with employee benefits, and to ensure that our tax and other statutory dues are paid and legal obligations are met.
Background InformationWe may collect information about you from references, corporate due diligence information, and background check information, including relevant criminal history and credit history.We use this information to verify your suitability for a role, and to ensure that you are qualified or equipped for the role for which you have applied. 
Benefits Enrollment and Administration InformationWe may collect information such as benefit selection information, Social Security Numbers or other government identification numbers, marital status, dependent and beneficiary information, including documents to establish dependent status, and leave of absence information.We use this information to administer benefits programs and process benefits claims. In some cases, we are required by law to collect this information.
Performance Management InformationWe may collect information such as employment status (full-time or part-time, regular or temporary); work schedule; job assignments; hours worked; business travel information; accomplishments and awards; training and development information; performance evaluation information; complaint resolution information; discipline and counseling information; and employment termination information.We use this information to evaluate and manage your performance and determine performance requirements. We also use this information to ensure high standards of behavior and performance across our business, and to appropriately handle performance, security, and behavioral issues in our workforce.
Demographic InformationWe may collect information you provide voluntarily to us about your gender/gender identity, race, ethnicity, veteran status, national origin, citizenship, gender expression, sexual orientation, religion, disability or accommodation requests.We use this information to carry out our business diversity and inclusion strategy. In some cases, we may be required by law to collect this information.
Health and Safety InformationWe may collect information such as medical or health conditions, job restrictions, drug testing information, workplace accident and illness information, and health insurance information.We use this information to maintain a safe working environment for all Work-Related Individuals and provide workplace accommodations to employees when necessary. We also use this information to administer employment related benefits, and to implement an effective sickness absences management system.
Electronic Communications InformationWe may collect information such as email, computer, internet, telephone, and mobile device usage utilizing Navy Federal networks or equipment, IP address, browsing history, login information, and geolocation information.We use this information to secure our information systems, prevent criminal activities and fraud, investigate claims of harassment or discrimination, and monitor employee conduct and performance.
Legal and Contractual InformationWe may collect information that we need in order to respond to law enforcement or governmental agency requests, comply with our contractual obligations, or protect our or someone else’s legal rights.We use this information to respond to such requests, fulfill such obligations, and protect such legal rights.
Biometric InformationWe may collect physical, biological, or behavioral characteristics that are used or intended to be used to establish individual identity. We use this information for authentication, fraud prevention, and security purposes.

B. Independent Contractors 

We may collect the following categories of Personal Information from you if you work with Navy Federal as an independent contractor: 

Categories of Independent Contractor Personal Information Collected
Context of Collection of Personal InformationTypes of Personal Information CollectedPrimary Purpose for Collection and Use of Personal Information
Contact InformationWe may collect your name, phone number, email address, and physical address.We use this information to contact you and communicate with you about our business relationship and the services you provide to Navy Federal.
Role InformationWe may collect information about your role preference and work availability, as well as the services you provide.We use this information to manage our business relationship with you, as well as to maintain efficient operations.
Pay InformationWe may collect pay rate/salary information, payroll deduction information, withholding tax information, banking information for direct deposit, and information required for expense reimbursement.We use this information to ensure that you are paid, and ensure that our tax and other statutory dues are paid and legal obligations are met.
QualificationsWe may collect information about your qualifications, experience, certifications, professional memberships, and education.We use this information to evaluate if you are qualified for certain contracts or workflows.
Background InformationWe may collect information about you from references, corporate due diligence information, and background check information, including relevant criminal history and credit history.We use this information to verify your suitability for certain contracts or workflows.
Billing & Payment InformationWe may collect W-9 Information, including business name, Social Security Number or Taxpayer Identification Number (TIN), billing, payment information, including bank name, account number, and routing number, and information about expenses.We use this information to fulfill our contractual obligation to pay you for services rendered.
Insurance InformationWe may collect information about insurance and bonding.We use this information to ensure that we have adequate and appropriate insurance coverage in place.
Electronic Communications InformationWe may collect information from electronic communications such as emails, IP addresses, browsing history, and telephone calls and voicemails.We use this information to manage our business relationship with you, as well as to secure our information systems.
Legal and Contractual InformationWe may collect information that we need in order to respond to law enforcement or governmental agency requests, comply with our contractual obligations, or protect our or someone else’s legal rights.We use this information to respond to such requests, fulfill such obligations, and protect such legal rights.
Biometric InformationWe may collect physical, biological, or behavioral characteristics that are used or intended to be used to establish individual identity. We use this information for authentication, fraud prevention, and security purposes.

Disclosure of Your Personal Information

We may disclose Personal Information that we collect or you provide as described in this Privacy Notice:

  • To our corporate affiliates (e.g., subsidiaries or other companies under common control). If another company acquires or plans to acquire our company, business, or assets, we will also share information with that company, including at the negotiation stage.
  • To service providers, which are companies we use to support our business and which are bound by law and contractual obligations to keep your Personal Information confidential. Service providers may use information we share with them only for the purposes for which we disclose it to them. The categories of service providers that we share information with and the services they provide are:
    • Payroll services providers that assist us in calculating and disbursing your salary and other compensation.
    • Auditing and accounting firms, such as firms that assist us in the creation of our financial records.
    • Professional services consultants, such as firms that perform analytics, assist with improving our business, provide legal services, or supply project-based resources and assistance.
    • Recruitment vendors that assist with the application process, including assessing candidate qualifications and providing the platform through which candidates submit their candidacy.
    • Security vendors, such as entities that assist with security incident verification and response, service notifications, and fraud prevention.
    • IT vendors, such as entities that assist with website design, hosting, and maintenance; data and software storage; and network operation.
  • In response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third-party intermediary.
  • To other third parties when we have your consent or direction to do so. 

How We Protect and Retain Personal Information 

No method of transmission over the internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your Personal Information from unauthorized access, use, or disclosure, we cannot guarantee the security of your Personal Information. In the event that we are required by applicable law to inform you of a breach to your Personal Information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements. 

In some circumstances, we may anonymize or deidentify your Personal Information so that it can no longer be associated with you, in which case we may use such information without further notice to you. To the extent we maintain and use Personal Information in an anonymized or deidentified form, we will not attempt to reidentify the information, except for the purpose of determining whether our anonymization/deidentification processes satisfy our legal obligations. 

Changes to This Notice

As we strive to improve our practices, we may revise this Notice from time to time. We reserve the right to change this policy at any time and to notify you of those changes by posting an updated version of this policy. We may also notify you in other ways from time to time about the processing of your Personal Information. 

Special Information for California Residents

California law requires us to disclose the following additional information related to our privacy practices. If you are a California resident, and to the extent the California Consumer Privacy Act applies to us,  the following privacy disclosures apply to you in addition to the rest of the Privacy Policy.

A. Notice at Collection  

California law requires that organizations disclose whether certain categories of Personal Information are collected, disclosed to third parties for a “business purpose,” or “sold” or transferred for “valuable consideration.” The table below indicates certain categories of Personal Information we collect and disclose to third parties in a variety of contexts. Note that we do not sell or transfer your Personal Information for valuable consideration or share it for the purpose of cross-context behavioral advertising. For details regarding how we use Personal Information, please see the Information We Collect About You section of the Workplace Privacy Notice. For information regarding how long we retain Personal Information, please refer to the How We Protect and Retain Information section of the Workplace Privacy Notice.

Personal Information We Collect and How We Use It
Categories of Personal Information We May CollectTo Whom We May Disclose Personal Information for a Business Purpose
Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers.We may share this information with affiliates or subsidiaries, business partners, government entities as may be needed to comply with law or prevent illegal activity, internet service providers, operating systems and platforms, other service providers, payment processors and financial institutions, and professional services organizations, which may include auditors and law firms.
Government-Issued Identification – this may include Social Security Number, driver’s license number, state-issued identification number, or passport number.We may share this information with affiliates or subsidiaries, government entities as may be needed to comply with law or prevent illegal activity, operating systems and platforms, other service providers, payment processors and financial institutions, and professional services organizations, which may include auditors and law firms.
Financial information – this may include bank account number, credit card number, and debit card number.We may share this information with affiliates or subsidiaries, government entities as may be needed to comply with law or prevent illegal activity, operating systems and platforms, other service providers, payment processors and financial institutions, and professional services organizations, which may include auditors and law firms.
Health-related information – this may include medical information, mental or physical condition or treatment, or health insurance information.We may share this information with affiliates or subsidiaries, service providers, business partners, government entities as may be needed to comply with law or prevent illegal activity, and professional services organizations, which may include auditors and law firms.
Characteristics of protected classifications – this may include age, sex, race, ethnicity, or physical or mental disability.We may share this information with affiliates or subsidiaries, business partners, other service providers, government entities as may be needed to comply with law or prevent illegal activity, and professional services organizations, which may include auditors and law firms.
Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.We may share this information with affiliates or subsidiaries, business partners, other service providers, payment processors and financial institutions, and government entities as may be needed to comply with law or prevent illegal activity.
Biometric information – this may include imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.We may share this information with affiliates or subsidiaries, operating systems and platforms, other service providers, and government entities as may be needed to comply with law or prevent illegal activity, and professional services organizations, which may include auditors and law firms.
Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.We may share this information with affiliates or subsidiaries, operating systems and platforms, other service providers, and government entities as may be needed to comply with law or prevent illegal activity, and professional services organizations, which may include auditors and law firms.
Geolocation dataWe may share this information with affiliates or subsidiaries, business partners, other service providers, government entities as may be needed to comply with law or prevent illegal activity, and professional services organizations, which may include auditors and law firms.
Audio, electronic, visual, thermal, olfactory, or similar informationWe may share this information with affiliates or subsidiaries, business partners, other service providers, government entities as may be needed to comply with law or prevent illegal activity, and professional services organizations, which may include auditors and law firms.
Professional or employment-related informationWe may share this information with affiliates or subsidiaries, business partners, service providers, government entities as may be needed to comply with law or prevent illegal activity, and professional services organizations, which may include auditors and law firms.
Non-public education information (as defined in the Family Educational Rights and Privacy Act)We may share this information with affiliates or subsidiaries, business partners, government entities as may be needed to comply with law or prevent illegal activity, and professional services organizations, which may include auditors and law firms.
Inferences drawn from any of the information listed aboveWe may share this information with affiliates or subsidiaries, service providers, business partners, government entities as may be needed to comply with law or prevent illegal activity, and professional services organizations, which may include auditors and law firms.
Additional categories of Personal Information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this may include signature, physical characteristics or description, or insurance policy number.We may share this information with affiliates or subsidiaries, service providers, business partners, government entities as may be needed to comply with law or prevent illegal activity, and professional services organizations, which may include auditors and law firms.

B. Sensitive Information

California law also requires businesses to disclose additional information with respect to categories of sensitive Personal Information they collect. Please see the chart below for further information about how Navy Federal collects and shares sensitive Personal Information. 

Sensitive Information Collected and How It Is Shared
Categories of Sensitive Personal Information We May CollectPurposes for Which It Is CollectedIs Information Sold or Shared for the Purpose of Cross-Context Behavioral AdvertisingLength of Time Company Intends to Retain Information
Social security, driver’s license, state identification card, or passport number.
  • To comply with our legal obligations of employment and hiring.
  • Business travel.
NoUntil no longer needed to comply with our legal obligations.
Account login, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
  • To comply with our obligations of employment.
  • To provide account-related functionalities to our employees.
NoUntil deletion of the account or until no longer needed to comply with our legal obligations of employment.
Racial or ethnic origin, religious or philosophical beliefs, or union membership.
  • To comply with our obligations under law for employment and hiring purposes.
  • To promote internal strategic initiatives such as diversity, including, and belonging.
NoUntil no longer needed to comply with our legal obligations.
Biometric information for the purpose of uniquely identifying an employee
  • We use this information to secure our information systems and prevent criminal activities and fraud.
NoUntil no longer needed to comply with our legal obligations.
Geolocation
  • We use this information to secure our information systems, prevent criminal activities and fraud, and monitor employee conduct and performance.
NoUntil no longer needed to comply with our legal obligations.
Contents of mail, email, and text messages unless the business is the intended recipient of the communication
  • For the purposes outlined in the employee handbooks.
NoUntil no longer needed to comply with our legal obligations.
Health information
  • To administer benefits and to comply with our legal obligations of providing accessible work accommodations and medical leave.
NoUntil no longer needed to comply with our legal obligations.

C. Your Rights 

California law provides California residents with the right to make certain choices about your Personal Information: 

  • Access: You may have the right to request access to Personal Information and information regarding the source of that information, the purposes for which we collected it, and the third parties and service providers with whom we shared it. In certain limited circumstances, you may also request to receive access to your data in a portable, machine-readable format.
  • Deletion: You may have the right to request that such Personal Information be deleted. Note that in many situations, we may be permitted or required by law to maintain copies of your information.
  • Modification: You may have the right to request modification to Personal Information that we retain about you. We generally rely on you to update and correct your Personal Information. Note that we may keep historical information in our backup files as permitted by law.
  • Objection to Certain Processing: Some jurisdictions provide consumers the right to opt out of the sale of Personal Information or sharing of such information for cross-context behavioral advertising by a company to third parties. However, we do not sell or share your Personal Information in this manner to any third parties and so are not required to provide a right to opt out. Please note that the right to opt out does not apply to our sharing of data with service providers, who are parties we engage to perform a function on our behalf and are legally and contractually obligated to use the data only for that function.
  • Objection to Processing of Sensitive Information: Some jurisdictions provide consumers the right to limit the business’s processing of sensitive Personal Information to that which is necessary to provide the services requested (here, to provide you with employment or manage our working relationship with you) and for certain other business purposes. We do not use the Personal Information of Work-Related Individuals for any purpose other than to provide you with employment, to manage our working relationship with you, and as otherwise allowed for by law. As a result, we are not obligated to further limit our processing of your sensitive Personal Information.

Please note, not all of the rights described above are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request because the law permits or requires us to do so, or if we are unable to adequately verify your identity. We will not discriminate against individuals who exercise their privacy rights under applicable law. 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.

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.

If you want to exercise any of the above rights, please contact us as indicated in the “How to Make Requests” section below.  Please note that in order to fulfil your request, we may need you to provide certain personal information to verify your identity. We may verify your identity in person, by phone call, or via email. Depending on your request, we may ask for additional information such as your name, your employee ID, or the name of your direct supervisor. We may also ask you to provide a signed and declaration confirming your identity.

You may be permitted to designate an authorized agent to submit a request on your behalf to access, correct, or delete your personal information. To do so, you must (1) provide that authorized agent written, signed permission to submit such request, and (2) verify your own identity directly with us.

If you are submitting a request on behalf of another person, please email us using the contact information below. You must provide written and notarized proof that you have been authorized by the individual to act on his or her behalf. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized to submit such request.

How to Make Requests

If you are a California resident, you or your authorized agent can use any of the following methods to make a request to exercise the rights described above.

Contact Us

If you have any questions about this privacy notice, or if you have a disability and need to access this privacy notice in an alternative format, please contact Navy Federal Employee Relations at the following information: