This Policy applies only to associates, job applicants, consultants, or contractors in California. For information on how Kohl’s, Inc., and its existing and future affiliates and subsidiaries handle Personal Information collected from applicable individuals who currently work or previously have worked for Kohl’s outside California, please refer to Kohl’s Policy 802 (Associate Privacy), which is available to Kohl’s associates through the myKohl’s intranet portal.
This Policy does not apply to other information collected online through our websites, mobile applications, social media pages, and through our direct marketing campaigns or other online communications (collectively the “Consumer Services”). Click here for more detail on our privacy practices related to our Consumer Services.
This Policy does not apply to requests to inspect personnel or payroll records made under statutes other than the California Privacy Rights Act (CPRA), including but not limited to Cal. Lab. Code §§ 226 or 1198.5.
NOTICE AT COLLECTION: We collect Personal Information identified below under “Information Collection” for the purposes described under “How Your Information Is Used.” For more information on your privacy rights, please see “Your California Privacy Rights” below.
TABLE OF CONTENTS
- Information Collection
- How Your Information is Collected
- How Your Information is Used
- How Your Information is Shared
- Your California Privacy Rights
- How Do We Handle Your Information
- Changes in Policy
- Contact Us
1. Information CollectionIn this Policy, we refer to “Personal Information,” which is information that identifies or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a Kohl’s associate, job applicant, contractor, or consultant. We collect the following categories of Personal Information:
- Identifiers/contact information: Your name, mailing address, email address, phone number, and unique identifiers associated with you.
- Characteristics of Protected Classifications under California or Federal Law: Your gender, gender identity, date of birth, veteran status, and disability.
- Professional or employment-related information:
- Your Resume / CV, cover letter, and any additional information you choose to share about your qualifications, experience, and area of interest.
- Ethnicity information you voluntarily provide during the hiring process and other diversity data, including your family status, or other self-identifiers you voluntarily provide in support of our diversity and inclusion programs.
- Recruitment information, such as your references, employment application, consumer reports and background checks (e.g., criminal checks, investigative consumer reports, credit checks, MVRs).
- Performance information, such as performance reviews, attendance records, and disciplinary reports.
- Information relating to visas and work authorizations.
- Internet or other electronic network activity information: This includes your use of technology on Kohl’s networks and systems, including your user log-in information and passwords, network activity, email, and use of messaging systems, the Human Resources management system, and associate training programs.
- Audio and Visual Information: In some locations, your image or information about your movement is captured via surveillance equipment. We may also collect audio information, such as capturing video that may contain your voice.
- Biometric Information: In some locations, you may use biometric equipment, devices, systems or software that utilize a scan of your finger, hand, face, retina, iris, or voiceprint for timekeeping, secure entry/exit, temperature/wellness screenings, security or safety monitoring, to unlock or use a device, or for other business purposes, which is then converted into a template or mathematical representation that is stored on the device or housed on a server.
- Education information: Information you share about your educational qualifications and anticipated graduation date (where applicable).
- Personal Information described in Subdivision (e) of Section 1798.80 not otherwise listed above: This includes financial payment or payroll information, such as your banking and direct deposit information, salary, tax information and forms, expense reimbursement records, and Paid Time Off (PTO) balances; benefits information, such as your benefits elections, beneficiaries, spousal or partner information and dependent information; or other information we collect for Human Resources, procurement, or business operations purposes.
- Inferences: The inferences that we draw from the above categories of Personal Information.
- Other information you provide: As part of the recruitment, job application, or intake processes, you may provide Kohl’s with additional Personal Information, including answers to application-related questions.
- Sensitive Personal Information: This includes your government-issued identification numbers (Government or national identification information, such as your driver’s license number, passport number, national insurance or Social Security number), Biometric Information, and health condition, or self-identifiers you voluntarily provide in support of our diversity and inclusion programs, including but not limited to sexual orientation, ethnicity, or nationality.
2. How Your Information is CollectedYour information is collected in the following ways:
- Your Personal Information is collected throughout your employment with Kohl’s and during the recruitment and application process, including the information you provide directly to us or via third-party service providers (e.g., payroll and benefits services, associate communication software and programs, etc.), as well as the information we obtain in connection with your employment activities and our day-to-day Human Resources and business operations.
- Your Personal Information is collected throughout the duration of your consultancy or position as a contractor. This includes information obtained when operating on Kohl’s networks.
- If you attend events, presentations, or other activities offered to associates, applicants, consultants, and contractors, then we may capture video and photographs that may contain your voice or image. We may use these images, recordings and videos through any media, including, without limitation, commercial internet sites, in print, or elsewhere for art, advertising, trade, promotion, sale or any other lawful purpose whatsoever, without notice or compensation to you.
- We may acquire Personal Information from you or from other trusted sources to update or supplement the information that you provide (for example, from your previous employers). We may combine the information we receive from and about you.
3. How Your Information is UsedYour Personal Information is used to support Kohl’s Human Resources and business operations, including, without limitation for the following business purposes:
- Personnel management, such as monitoring and evaluating performance, training, day-to-day management, associate communications and responding to your requests, inquiries and comments;
- Operational purposes, such as distributing payroll and benefits, updating and managing personnel files, conducting audits and providing IT support and other troubleshooting;
- Security purposes, such as to protect associates, applicants, consultants, contractors, visitors, the public, customers, vendors, Kohl’s and its property;
- Emergency purposes;
- Legal and compliance purposes, such as implementing internal policies, responding to suspected fraud or other illegal activity, protecting the rights and property of Kohl’s and others, and complying with laws, legal processes, and governmental requests.
- Certain members of the Human Resources community, Kohl’s Diversity & Inclusion Council, our legal teams, and consultants and vendors retained by those teams will be able to view and use certain pieces of Personal Information (e.g., race, gender, etc.) for diversity, inclusion, workforce or organizational development, legal compliance and related business purposes. The information provided will be kept as confidential as possible, although it may be disclosed in summary or aggregate form to government regulators, as required by law, and utilized by Kohl’s in its diversity and inclusion efforts. We may also share military or veteran status within the Kohl’s community in connection with recognition and appreciation events and publications.
- We use the Personal Information we collect for purposes of determining your qualifications for employment or a contract and to potentially correspond with you.
- To the extent that we communicate with you in connection with any of the foregoing, we may do so via text message, email, interactive voice response message and other messaging services (whether auto-dialed or recorded) or other means as reasonably determined by Kohl’s. Message and data rates may apply, for which you are responsible unless otherwise required by applicable law.
4. How Your Information is Disclosed
- We may disclose each category of Personal Information identified above under “Information Collection” for business purposes identified above under “How your information is used” including, without limitation, to the following categories of entities:
- With service providers with whom we have engaged to perform certain Human Resources and/or business operations functions on our behalf (including to operate the Kohl’s Careers website and our HR management tools);
- With legal or regulatory authorities and other external third-parties when required by law, court order or legal or regulatory process or to protect the rights and property of associates, visitors, the public, customers, vendors, and Kohl’s. It could also include sharing information if a government agency or investigatory body requests. We may share information when we are investigating a potential fraud;
- When required for a business-related purpose involving company assets, financing, sale or acquisition. For example, if Kohl's merges with, acquires or is acquired by another business entity. This may include an asset sale, corporate reorganization or other change of control;
- Within the Kohl's family of companies. This includes our affiliates;
- With your consent and at your direction;
- For other purposes as disclosed at the time you provide your information; and
- For any other lawful purpose.
In each case, Kohl’s will undertake reasonable and lawful action to ensure that any use or disclosure of your Personal Information complies with applicable law and is limited to the extent reasonably necessary under the circumstances, as determined by Kohl’s in its sole discretion.
We do not “sell” or “share” your Personal Information as these terms are defined in applicable law.
5. Your California Privacy RightsIf you are a California resident, you may take advantage of the following privacy rights:
- Right to Know: You have the right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom we disclose Personal Information, and the specific pieces of Personal Information we have collected about you. Click here if you wish to exercise your Right to Know.
- Right to Delete: You may request that we delete the Personal Information that we have collected from or about you. Note that there are some reasons when we will not be able to fully address your request, such as to perform a contract, to detect and protect against fraudulent and illegal activity, to maintain for internal purposes, to comply with a legal obligation, or to preserve or exercise our rights. Click here if you wish to exercise your Right to Delete.
- Right to Correct: You have the right to correct inaccurate Personal Information that we may maintain about you, subject to appropriate verification. Click here if you wish to exercise your Right to Correct.
- Right to Opt Out: You have the right to opt out of the sale or sharing of your personal information and to limit the use of your sensitive personal information. Click here if you wish to exercise your Right to Opt Out.
Right to Non-Discrimination. You have a right not to receive discriminatory treatment from Kohl’s for exercising your privacy rights conferred by law.
Use and Disclosure of Sensitive Personal Information. To the extent that we collect, use, or share “sensitive personal information” as that term is defined in applicable California privacy laws, we limit our use or disclosure of such information for permitted business purposes.
Information on Requests Received During the Prior Calendar Year: Click here.
How to Submit a Request. Use these links to take advantage of your Right to Know, Delete, or Correct under California law, or contact the HR Data Privacy team at HRprivacy@kohls.com. Please be aware, this email address is solely dedicated to communication related to this Policy or requests made pursuant to the California Privacy Rights Act (CPRA). Please do not utilize this address for any other type of inquiry.
Authorized Agent Requests. You may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you’ve authorized them to act on your behalf. Kohl’s retains the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity.
6. How Do We Handle Your InformationThe Internet is not 100% secure. We cannot promise that your use of our sites will be completely safe. We encourage you to use caution when using the Internet. We use reasonable means to safeguard Personal Information under our control. We limit Personal Information access to those associates, agents, contractors, and other third parties that have a legitimate business need for such access.
We retain your Personal Information as required by applicable law or for as long as is reasonably required for our business purposes in accordance with Kohl’s record retention and/or other applicable policy. This includes us securely deleting or destroying information in a job applicant file, in a manner consistent with applicable law, if we decide not to offer employment, consultancy, or a contractor position to you. Otherwise, we may keep your Personal Information for up to six (6) years, or otherwise as required by applicable law or for as long as is reasonably required for our business purposes, after a decision not to employ you (or contract/consult with you), an offer of employment that you do not accept, an offer for a consultant or contractor position that you do not accept, or termination of your employment (or contract/consultancy).
7. Changes in PolicyWe reserve the right, at our sole discretion, to change, modify, add, remove, or otherwise revise portions of this Policy at any time. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy here.
8. Contact UsIf you have any questions about this Policy or a request related to HR data privacy rights under the California Privacy Rights Act (CPRA), please contact the HR Data Privacy Team at HRprivacy@kohls.com. Please be aware, this email address is solely dedicated to communication related to this Policy or requests made pursuant to the California Privacy Rights Act (CPRA). Please do not utilize this address for any other type of inquiry.
For questions about completing a job application, job application status, or the job application process generally, please click here to submit your question, or visit Kohl’s job applicant FAQs here.
Our general contact information is: (1) by telephone, (262) 703-7000, or (2) by mail, Kohl's, Inc., N56 W17000 Ridgewood Drive, Menomonee Falls, WI 53051. Do not use Kohl’s general contact information to submit any requests related to your rights under the California Privacy Rights Act (CPRA), or any questions about this Policy or Kohl’s use of your Personal Information.