For purposes of employment in the United States, Sirius is required to collect information and maintain records on:
(a) individuals seeking employment including information on: name, education, work history, sex, ethnicity/race, disability, and veteran status for purposes of candidate/applicant data collection, analyses, and reporting;
(b) individuals offered employment including information on: name(s), residence(s), education, work history, sex, ethnicity/race, disability, and veteran status; in addition to Social Security numbers, date of birth, and identification information such as state driver’s licenses for purposes of completing pre-employment background checks and drug tests; and
(c) new hires and employees including:
• Human Resource Information Systems (HRIS) including information on: name, residence(s), education, work history, Social Security numbers, date of birth, sex, ethnicity/race, disability, and veteran status, deductions from pay, rates of pay and earnings consistent with U.S. Department of Labor recordkeeping regulations.
• Employment Verification Eligibility (EVE) Form and E-Verify System, including: an Attestation of personal information (name, residence, date of birth, Social Security number, citizenship status, alien registration number, and work authorization expiration date), and documents:
✓ Establishing identity and U.S. work eligibility (such as a U.S. passport or Employee Authorization Document (EAD); or
✓ Establishing identity (non-U.S. passport with a valid work permit, or a state-issued driver’s license or ID, or a U.S. military ID), and
✓ Establishing U.S work eligibility (such as a Social Security card, birth certificate issued by a government, or EAD)
• Immigration documents for work sponsorship including information on: name, residence(s), educational degree(s) and course work, work history, passport information, birth certificate, marriage certificate(s), job titles, and dependents.
• Requests for accommodations for disability and medical conditions, along with self-identification forms and implemented accommodations, are maintained in a confidential and secure data file separated from HR records and systems.
• Company benefits including name, residence(s), Social Security numbers, date of birth, sex, information on pay and deductions from pay, and number of dependents.
More specifically:
• Job seeker information, including resumes and employment applications, is retained in the Company’s candidate/applicant system for three years.
• Employee information is typically maintained in the Company’s HRIS system and used for a number of human resource applications including government reports (such as tax and demographics) and analyses (including annual Affirmative Action Plans), typically retained for three to five years after employment ends, and subject to audit by the Department of Labor (DOL).
• Employment Verification Eligibility forms are maintained by a third party and submitted to the Department of Homeland Security (DHS) and Social Security Administration (SSA) for review and approval, retained for at least three years after employment ends, and subject to audit by DHS.
• Immigration information is maintained by a third-party immigration counsel, submitted to the DOL, DHS, and Department of State for review and approval, and maintained by the Company in required Public Access Information files subject to audit by DHS.
• Accommodation information is maintained in a confidential secure data file and used for aggregate data collection and reporting and subject to audit by DOL.
• Benefits and medical information maintained by a third-party provider is used for determining leaves of absence and tax reporting, retained for at least five years after employment ends, and subject to audit by the DOL.
The Company has developed Employee Data Privacy Guidelines and a Record Retention Schedule. Questions concerning the Employee Data Privacy Guidelines should be directed to the HR Compliance Department.