- the information that you provided to us during the recruitment process, including your resume or curriculum vitae, application form, work history, education, degrees, academic records, languages and qualifications, references and any professional licenses, memberships, or certifications;
- your basic contact and demographic information, including your name, address, telephone numbers (home, mobile/cell, work), email address, citizenship/nationality, date and place of birth, gender, and work permit information if applicable;
- your government issued identifiers subject to the conditions of applicable law, such as your national ID details, tax identification number, social security or national insurance number, passport number, and, where required for your job, your driver’s license number;
- your bank and financial details for salary/payroll purposes, such as your salary, other remuneration, your IBAN number or bank account number, and bank name, routing number and details;
- information about your job and position, including the employee identification number, badge number, job title and description, department and manager, reporting lines, work location, cost center, business unit or group, work status such as full time or part time, working hours, probation period if applicable, and employment terms and conditions;
- information for use of Nike network and devices if applicable, such as username, password, contact details, work telephone number and device data (computer, telephone, tablet ID number), company photo, if provided; and
- information about your personal or family life, including marital status, dependents, beneficiaries and partner/spouse, and emergency contact information.
We may maintain the information we collect when we conduct pre-employment verification of your identity, address, or references and, where permitted by local law, the verification of background checks (including criminal or judicial data) about you, in accordance with Nike’s Background Checks Policy.
Human Resources Management
We collect Personal Information that is generated during your employment as necessary to help manage your working relationship with Nike. This includes:
- information about your working hours and leaves, including attendance, holiday/vacation, leaves or absences, travel and mobility;
- economic and financial information for compensation and benefits, including your banking and account details for remuneration and compensation, information on raises and bonuses, your benefits package and information and details associated with pensions or insurance programs that may be offered in your country;
- information related to your work evaluations and performance, including regular evaluation details, reviews and feedback, details about performance plans, and information associated with professional development such as trainings (both internal and external), courses, seminars and conferences, and succession planning information;
- information collected for travel and expense purposes, such as credit card information, bank details (e.g., account and routing numbers, IBAN, etc.), booking and itinerary details, passport information (e.g., number, expiration, issuing authority, etc.), visa and immigration information, and travel preferences (e.g., seat preference, dietary restrictions, and frequent flyer and corporate memberships, if provided);
- information associated with mobility, transfers and relocation (either upon hiring or as part of a transfer or work assignment), including family details, immigration status and nationality/citizenship, and tax and social security information.; and
- information about your participation in and the administration of the Nike Employee Stock Purchase Plan (ESPP –which is a voluntary incentive program, please also see paragraph 6) and bonus grants, including your contact information, national tax information (including national identifier), nationality, job title, shares and position, details of purchases and entitlements to shares awarded, cancelled, exercised, (un)vested or outstanding for implementing, administering and managing the ESPP.
- We monitor our facilities and use CCTV for employee safety, security and other legitimate business purposes, such as loss prevention. The facilities that use CCTV display visible signage where this is required by applicable law. We may use camera footage or recordings in those facilities to protect the legitimate interests or to defend the legal rights of Nike as permitted by applicable law.
- We also process Personal Information associated with the protection of employee health and safety in workplaces, including contact details and other Personal Information (such as driver’s license details), as well as a description of the accident or injury and any remediation.
- Additionally, we process information about your use of Nike devices, technology and network to pursue our legitimate interest in securing our information and information systems. More information about these practices is described in Nike’s Acceptable Use Policy.
- In exceptional cases, we may need to process your Personal Information if it is necessary to protect your vital interests such as in case an accident happens at work or during work business travel.
- We strive to obtain Personal Information directly from you to keep it accurate, up to date and relevant. Collection of Personal Information may occur during the job application process, during the employee on-boarding process, or on an ad hoc basis throughout your employment.
- We also receive Personal Information about you from your line manager (for example, for performance or annual reviews) or from other colleagues (for example, in the context of periodic reviews or evaluations or if conducting a disciplinary investigation). From time to time, we may receive Personal Information about you from other third parties, for example customers, store partners, companies such as benefits providers, educational institutions, former employers, professional networking websites, professional references, members of the public and regulatory bodies. We may also receive Personal Information from our websites, apps, systems, and network, as well as our third-party service providers.
- We share your Personal Information with other Nike entities for administrative purposes where required to run global processes, carry out group-wide reporting, or make decisions about senior hires or promotions based on our legitimate interest to administer our HR operations. This is typically administered by our People Solutions service centers serving Asia, Europe, and the rest of the world; these are located in Singapore (Nike Trading Company B.V., Singapore Branch), the Netherlands (Nike European Operations Netherlands B.V.) and the U.S.A. (Nike, Inc.) respectively.
- As a global company, Nike relies on service providers and vendors that provide products and services. Nike may disclose the categories of Personal Information listed above to these third parties based on our legitimate interest to engage third parties where necessary for the purpose of achieving the objectives outlined above. These include accountants, law firms and legal service providers, tax or financial professionals, payroll and benefits providers, relocation companies, pension and insurance companies, human resources specialists, consultants, contractors, IT support and storage providers. We do not sell or share your Personal Information for advertising purposes.
- Our third-party service providers may have access to your Personal Information to perform certain functions or may host your Personal Information as part of a “cloud based” solution used by Nike employees. Nike uses third-party service providers that provide sufficient guarantees for the protection of your Personal Information. All vendors are to undergo Nike’s vendor risk assessment. Nike requires third-party service providers by contract to implement appropriate data security and confidentiality obligations, in accordance with applicable law.
5. Security and Governance of Personal information
- Nike implements physical, technical and administrative security measures that are intended to protect your Personal Information. Please see Nike’s Information Security Program(“NISP”) for more information.
- We also implement access controls to help ensure that access to Personal Information is limited to Nike personnel who need to have access to perform their duties. Please see the Enterprise Data Access Policy for more information.
6. Retention of Personal information
We will retain the Personal Information we collect for as long as reasonably necessary to support our ongoing legitimate business needs and to carry out the purposes described in this Policy or as otherwise required by applicable law. Generally, this means your Personal Information will be retained until the end of your employment or work relationship with us plus a reasonable period of time thereafter as required (1) to effectuate termination of our relationship, (2) by applicable law or regulation, (3) to respond to employment or work-related inquiries or issues, or (4) to provide you with ongoing pensions or other benefits. If you continue to receive benefits from us after the end of your employment, we will continue to manage and process your Personal Information as described above. For more information about Nike's data retention practices, including in respect of employee records, please refer to Nike's Records Retention Policy.
7. Updates to this Policy
We may change, update, or modify this Policy from time to time. If we make any changes to this Policy that materially affect our practices regarding the Personal Information we have previously collected from you, we will endeavor to provide you with notice in advance of such change, such as by contacting you at the email address we have on record.
8. Contact Information
If you have questions regarding this Policy, please contact your local HR manager. You may also contact Nike’s Privacy Office or Data Protection Officer by emailing privacy.office@nike.com.
Additional Information for California Residents
If you reside in California, the following additional California-specific provisions apply to the processing of your Personal Information:
This California Employee Privacy Policy and Notice at Collection (“Employee Notice”) provides specific information for residents of California who work for Nike. This Employee Notice is intended to satisfy our applicable notice requirements under the California Consumer Privacy Act (“CCPA”) (Cal Civ. Code § 1798.100 et seq.), as amended by the California Privacy Rights Act (“CPRA”).
Personal Information for purposes of this Employee Notice does not include:
· Publicly available information that is lawfully made available from federal government records;
· Information we have a reasonable basis to believe is lawfully made available to the general public by you, by widely-distributed media, or by a person to whom you have disclosed the information and not restricted it to a specific audience;
· Information that is deidentified or aggregated;
· Protected Health Information that is governed by the Health Insurance Portability and Accountability Act ("HIPAA"); and
· Information we receive from consumer reporting agencies that are subject to the Fair Credit Reporting Act ("FCRA") (e.g., information contained in background check reports we obtain as part of our hiring process).
1. Information We Collect
As further discussed in “Types of Personal Information We Collect and How We Use Them” above, the table below identifies, generally, the categories of Personal Information about you that we may collect, and that we have collected in the previous 12 months, about California residents in their capacity as Nike employees. Some Personal Information included in the categories below may overlap with other categories.
Categories of Personal Information
Categories of Sources
Disclosed for a Business or Commercial Purpose
Have we Sold or Shared in the Past 12 Months?
Identifiers
- Including name, former last name, suffix, alias, address, email address, date of birth, unique personal identifier, online identifier, Internet Protocol (IP) address, social security number, driver’s license number, passport number, or other similar identifiers.
- From you directly.
- From other businesses (e.g., benefits providers).
- From publicly available sources such as company websites or professional networking sites.
- From professional references.
Characteristics of protected classifications
- Including age, race, ancestry, national origin, citizenship, marital status, pregnancy, medical condition, physical or mental disability, sex, veteran or military status and other characteristics of protected classifications under California or federal law.
- From you directly.
- From other businesses (e.g., benefits providers).
Professional or employment-related information
- Including current and former employer(s), employee ID, office phone number, company cell number, work email, employment history, qualifications, professional memberships, licensing, disciplinary record, or any other related information.
- From you directly.
- From publicly available sources such as company websites or professional networking sites.
- From professional references.
Internet or other electronic network activity information
- Including browsing history, interactions with our systems, networks and applications.
- From you directly.
- Through our websites, mobile apps, systems, networks, and online services.
- From third-party service providers.
General geolocation data
- Location information about a particular individual or device.
- From you directly.
- Through our websites, mobile apps, and online services.
- From third-party service providers.
Audio, visual, or similar information
- Such as audio, electronic, visual, or similar information, including information collected via call recordings, recorded meetings, videos, photographs, and CCTV footage to secure our offices and premises.
- From you directly.
- From third-party service providers.
Education information
- Including education records, including schools attended, degrees awarded, dates of attendance, grades, transcripts, student disciplinary records, or any other related information.
- Information about education history or background that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
- From you directly.
- From educational institutions or providers of educational or professional certification information.
Sensitive Personal Information
- Such as social security number, driver’s license number, precise geolocation information derived from a Nike device, state identification card, passport number, racial or ethnic origin, medical conditions, physical or mental disability, sexual orientation, Nike account login credentials, financial account information, and the content of your emails and other electronic messages sent using a Nike account, device, app, platform, or system.
- From you directly.
- Through our websites, mobile apps, and online services.
Profiles and inferences
- Inferences drawn from any of the information identified above to create a profile reflecting an individual’s preferences, characteristics, behavior or attitudes.
- From you directly.
2. Sales and Sharing of Personal Information
We do not sell or share, as those terms are defined under the CCPA, Personal Information or sensitive Personal Information about employees, including those who we know are under 16 years old.
3. How We Use Information
Generally, we may use the categories of Personal Information described above for the following business or commercial purposes (and any directly related purposes), as further described in "Types of Personal Information We Collect and How We Use Them" above:
- Onboarding
- Human resources management
- Safety and security
- Offboarding
- Voluntary programs
- Sensitive data processing
- Compliance with legal obligations
- Defending and protecting rights
- Mergers, acquisitions and other business transactions
- Auditing, accounting, reporting and corporate governance
- Other legitimate business purposes
Use of Sensitive Personal Information. Our collection, use and disclosure of sensitive Personal Information is generally limited to what is reasonable and proportionate for the following purposes:
- To comply with our legal, regulatory and reporting obligations;
- To make reasonable accommodations where necessary;
- To verify the information you provide to us;
- As otherwise necessary to carry out our functions as an employer;
- In support of our equal opportunity and diversity and inclusion efforts (on a voluntary basis);
- Where necessary to protect the health and safety of an individual; and
- To protect and take action against malicious, deceptive, fraudulent, or illegal actions, security incidents.
We do not use or disclose employee sensitive Personal Information for purposes except as described herein (and as permitted pursuant to Cal. Code Regs. tit. 11, § 7027(m) (2022)).
4. Disclosures of Personal Information
As further described in “Disclosures of Personal Information” above, we may disclose or have in the previous 12 months disclosed the above categories of Personal Information for a business purpose to the following categories of recipients on a need-to-know basis:
- Our personnel, including personnel of our affiliates;
- Service providers and vendors that act on our behalf to process Personal Information for administrative, management, or business purposes and to assist us in providing our products and services. These include accountants, law firms and legal service providers, tax or financial professionals, payroll and benefits providers, relocation companies, pension and insurance companies, human resources specialists, consultants, contractors, and IT support and storage providers;
- Third-party researchers and publishers;
- Governmental bodies, law enforcement, or regulatory authorities where required by applicable law, in the context of lawful requests, court orders, legal proceedings or investigations;
- Potential or prospective buyers, sellers, lenders and their respective affiliates, agents, advisers, representatives, employees, and officers in event of corporate transactions such as a financing, merger, acquisition, takeover, bankruptcy, amalgamation, reorganization or other sale or disposal of assets or interests; and
- Third-party platforms and providers.
If required under the CCPA, we will obtain your consent prior to disclosing your Personal Information.
5. Data Retention
We will retain the Personal Information we collect for as long as reasonably necessary to support our ongoing legitimate business needs and to carry out the purposes described in this Policy or as otherwise required by applicable law. Generally, this means your Personal Information will be retained until the end of your employment or work relationship with us plus a reasonable period of time thereafter as required (1) to effectuate termination of our relationship, (2) by applicable law or regulation, (3) to respond to employment or work-related inquiries or issues, or (4) to provide you with ongoing pensions or other benefits. If you continue to receive benefits from us after the end of your employment, we will continue to manage and process your Personal Information as described above. For more information about Nike's data retention practices, including in respect of employee records, please refer to Nike's Records Retention Policy.
6. Your California Privacy Rights
Under the CCPA, employees who reside in California have the following rights (subject to certain conditions, limitations and exceptions) regarding the Personal Information we collect. Importantly, these rights do not affect other rights you may have under the California Labor Code.
- Right to Know/Request Access. 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.
- Right to Correct. Subject to certain restrictions, you have the right to request that we correct inaccuracies in your Personal Information.
- Right to Delete. Subject to certain conditions and exceptions, you have the right to request deletion of your Personal Information that we have collected about you.
- Right to Opt-Out. You have the right to opt-out of “sales” and “sharing” of your Personal Information, as those terms are defined under the CCPA. However, we do not sell or share our employees’ Personal Information, so there is no need to exercise these rights.
- Right to Limit Use and Disclosure. We do not engage in uses or disclosures of Personal Information that would trigger the right to limit use of sensitive Personal Information under the CCPA.
- Right to Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.
Exercising Your California Privacy Rights
Employees who are California residents may submit a request to exercise their CCPA rights via the methods described below:
We will take steps to verify your request by providing you with instructions to authenticate your identity through our corporate systems and and/or matching the information provided by you with the information we have in our systems. We will process your request based upon the Personal Information in our records that is linked or reasonably linkable to the information provided in your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor.
Authorized agents may initiate a request on behalf of another individual using the same methods described above. Authorized agents will be required to provide proof of their authorization, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent. You may also provide us with a signed and dated power of attorney naming the authorized agent as your representative.
We reserve the right to reject (1) authorized agents who have not fulfilled the above requirements, or (2) automated rights requests where we have reason to believe the security of the requestor’s Personal Information may be at risk.
Response Timing and Format.
We endeavor to respond to a consumer request within 45 days of receipt. If we require more time (up to 90 days total), we will inform you of the reason and extension period in writing.
If we cannot respond to your request, either fully or partially, we will also explain our reasons. For data access requests, we will deliver the data in a readily, useable format.
Rights Under California Shine the Light Law. We do not share Personal Information of employees with third parties for their own direct marketing use.
Safety and Security
Offboarding
We collect and process Personal Information during offboarding to finalize the employment relationship and to comply with our legal obligations. This includes information associated with retirement and termination, such as details of retirement, resignation, layoffs/reorganization, including notice period, termination date, reason for leaving and termination, retirement, and pension administration arrangements.
Voluntary Programs
From time to time, we may offer voluntary employee programs that process Personal Information in which you may freely agree to participate.
Sensitive Personal Information Processing
During onboarding and throughout your employment relationship, we may collect sensitive Personal Information subject to the conditions of applicable law. Our collection, use, and disclosure of sensitive Personal Information is generally limited to what is reasonable and proportionate to the purpose for which we collect it. For example, you may need to provide us or our company doctor with medical information to allow us to manage illness, incapacity, or disability issues, or to make a reasonable accommodation. In some countries, you may provide us voluntarily with sensitive Personal Information, such as your race, ethnicity, religion or sexual orientation, for diversity and equal opportunities purposes and where required or permitted by law. We also may be required to collect sensitive data to comply with our legal requirements in the fields of employment, social security, social protection (e.g., wage liens, tax or social security number), and other applicable laws.
Compliance with Legal Obligations
We may use your Personal Information to comply with applicable legal obligations (such as determining hiring eligibility or responding to subpoenas and court orders) as well as assessments, reviews and reporting relating to such legal obligations, including under employment and labor laws and regulations, Social Security and tax laws, environmental regulations, workplace safety laws and regulations, and other applicable laws, regulations, opinions and guidance.
Defending and Protecting Rights
We may use your Personal Information to protect and defend our rights and interests and those of third parties, including to manage and respond to employee and other legal disputes, to respond to legal claims or disputes, and to otherwise establish, defend or protect our rights or interests, including without limitation, Nike’s trade secrets and other intellectual property; the rights, interests, property, health, safety and reputation of Nike and its workforce; and the rights, interests, property, health or safety of others, including in the context of anticipated or actual litigation with third parties.
Mergers, Acquisitions and Other Business Transactions
We may use your Personal Information for purposes of planning, due diligence and implementation of commercial transactions, such as mergers, acquisitions, asset sales or transfers, financings, bankruptcy or reorganization or other similar business transactions.
Auditing, Accounting, Reporting and Corporate Governance
We may use your Personal Information for purposes relating to financial, tax and accounting audits; audits and assessments of our business operations, including without limitation assessing the effectiveness of Nike's business processes and measuring employee engagement; ensuring business continuity in case of absence or departures from Nike; problem resolution (e.g., internal reviews, grievances); management of whistleblowing channels; internal investigations; compliance (including conflicts of interest); risk management and security purposes, including security controls and financial controls; compliance with applicable laws, regulations and legal obligations; and for other internal business purposes such as administering our records retention program.
Other Legitimate Business Purposes
We may use your Personal Information based on our legitimate interest as necessary to conduct investigations, defend Nike’s legal interests, exercise claims or litigation, and comply with judicial or regulatory orders. We may also need to maintain disciplinary and grievance records (such as records of allegations, investigations or audits), as permitted or required by law. We process Personal Information as necessary to operate Nike’s Speak Up Portal in accordance with Nike’s Code of Conduct (Inside the Lines).