Associate and Contractor Privacy Disclosure  

Last updated: April 24, 2025

This disclosure applies to Associates and Contractors in the following divisions:

UNFI Canada

 

Overview

This Associate and Contractor Privacy Disclosure (the “Privacy Disclosure”) contains the policies and procedures to be followed by United Natural Foods, Inc., including its present or future subsidiaries (the “Company,” “UNFI,” “we,” “us,” or “our”) related to the collection, use, monitoring, disclosure and disposal of Personal Information (as defined below) of a job applicant, an associate, a Company officer or director, or a contractor in Canada (referred to in this Privacy Disclosure as the “Associate/Contractor,” “you,” or “your”).  Note: A Contractor is a non-Associate who performs services for UNFI and may not be employed by the Company.  Certain sections of this Privacy Disclosure do not apply to Contractors.  Nothing in this Privacy Disclosure shall create an employment relationship between Company and Contractors.

UNFI wants you to understand how and why we collect “Personal Information,” which is any information about an identifiable individual including any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Associate/Contractor.  Associates/Contractors should have no expectation of privacy when using UNFI provided technology, UNFI owned or leased vehicles, or whenever accessing UNFI technology resources, networks, or information.

UNFI is committed to protecting the privacy of all our Associates/Contractors, and we take administrative, technological, and physical safeguards designed to protect your Personal Information from threats against its availability, integrity and confidentiality, including any unauthorized access, misuse, accidental loss, or alteration.

 

MANNER OF COLLECTION OF PERSONAL INFORMATION

Most Personal Information is collected directly from you through the job application and Associate/Contractor on-boarding processes, as well as through regular course of employment. The Company may also collect Personal Information indirectly, such as from information you have posted on professional networking sites (such as public LinkedIn profiles), through our service providers such as our fleet monitoring and third party background screening providers, and recruitment agencies. During the course of your employment, the Company also collects information through automated means about your use of company information technology systems.

What Information Do We Collect, Use and Disclose?

UNFI may collect, use and disclose various categories of Personal Information identified in Schedule 1 below, for the purposes described in that chart and generally to establish and administer the Associate/Contractor relationship, comply with legal obligations, facilitate communications and efficiency, provide benefits or to ensure the safety of Associates/Contractors, facilities and property, as more fully described below.

Reasons for Collection

1. Administer the Associate/Contractor Relationship

The Company needs to keep and process Personal Information for normal employment and contractor engagement purposes; this Personal Information may include identifiers such as user IDs, Associate/Contractor ID numbers, social insurance number, Associate/Contractor classifications for the purposes of the Company’s diversity program, and biometric information. The Personal Information we collect, hold, use, process and disclose will be used for management and administrative uses and only shared with others who have a need to know such information. We will keep and use it to enable us to run the business and manage our relationship with you effectively, lawfully and appropriately, during the recruitment process, while you are working for us, and after your employment or contract has ended. This includes using Personal Information to enable us to comply with any legal requirements associated with an Associate/Contractor relationship, to administer payroll, to provide you with benefits, to provide training, to ensure your safety, to comply with an employment or service contract, and to demonstrate our commitment to equal employment opportunity and fair employment practices. 

2. Comply with Legal Obligations

In certain situations, we may need to collect and process your Personal Information to comply with our legal obligations. This includes:

• Tracking demographic information to confirm compliance with equal opportunity and non-discrimination laws and requirements and any equal opportunity or diversity programs that the Company may have;
• Processing information relating to your health, which could include reasons for absence and doctor’s reports and notes, in order to comply with our obligations under applicable employment and safety and health laws; and/or
• Processing information relevant to any alleged violations of the Code of Conduct or other Company policies necessary to investigate allegations and institute disciplinary action as is required.

3. Facilitate Communications and Efficiency

The Company uses various tools and platforms that allow Associates/Contractors to more easily communicate with each other and to more efficiently access and share various types of work product and schedules.  Some tools may also allow Associates/Contractors to share information via social media or other channels, including information relating to job opportunities.

These tools and platforms may collect and share internally, contact information and company profile pictures; log certain preferences and actions; collect your geolocation; and create user profiles that allow Associates/Contractors and UNFI to track their efficiency and performance.

Please note that communication tools and platforms provided by the Company are monitored by the Company for appropriate usage and compliance with the Company’s policies.  Associates/Contractors should have no expectation of privacy in respect of their use of these tools and platforms.  The Company also monitors Associate/Contractor use of social media platforms while they are performing work for the Company. Inappropriate use of communication tools and platforms or social media by Associates/Contractors while performing work for the Company or use contrary to Company policies may lead to disciplinary action.  Postings on Company websites that disparage the Company’s reputation will be removed.

4. Provide Benefits

UNFI offers Associates a variety of benefits, including benefits related to healthcare, retirement savings, and the ability to order goods and services directly from the Company.  In doing so, the Company may collect Personal Information such as personal identifiers, demographic information, biometric data, geolocation data, purchasing information and employment information.  If Associates take advantage of other benefits, such as fitness-related benefits, the Company may also collect additional biometric and sensory information in order to provide the Associates with those benefits.  When you participate in certain benefits programs, the Company may also generate a log of your activity, track internet and other network activity while at work, and develop a user profile to provide those programs to you in a manner tailored to your preferences. 

The Company will collect Personal Information to provide benefits to Associates.  All benefits may not be available to all Associates. Associates should take care to read the specific terms applicable to any particular mobile application or benefits program to understand the specific pieces of information collected and the purposes for the collection.

5. Ensure the Safety of Associates, Contractors, Facilities, and Property

UNFI collects various categories of information to ensure the safety of Associates/Contractors, facilities and property.  Some Personal Information, such as personal identifiers and biometric information, help verify the identity of Associates/Contractors permitted to be on site in specific facilities.  Other categories of information, such as geolocation data and sensory data, which may be collected through mobile tracking devices, as well as video and audio recordings, may assist the Company with ensuring the security of facilities and Company vehicles.  These tools may process your Personal Information using artificial intelligence or similar technology.

 

Retention and Disposal of Personal Information

Any Personal Information collected by the Company will be retained by the Company during the period of active employment of the Associate or service relationship of the Contractor, as well as during the post-employment period only as long as the Personal Information is required to serve its original purpose or as directed by applicable legislation or regulation.  Personal Information that no longer meets those criteria will be destroyed, erased, or made anonymous in accordance with the Company’s document retention policies.

The Company will ensure that all practices and procedures relating to the disposal of Personal Information will respect the fundamental policy of confidentiality.  All Personal Information disposal procedures, including the disposal of computerized data storage devices, will be undertaken by a means designed to ensure the destruction of Personal Information to minimize the risk of subsequent unauthorized disclosure of Personal Information.

Service Providers

The Company uses affiliate and third-party service providers located outside of Canada, or the province in which you reside, to collect, use, disclose or store Personal Information on behalf of the Company for the purposes described in Schedule 1, below, for example payroll and benefits providers.   Please contact our Chief Privacy Officer listed below for more information about the Company’s policies and practices with respect to its use of service providers located outside your jurisdiction.

Access

Associates/Contractors have the right to access the Personal Information that the Company holds about them, to learn the ways in which the information has been used by the Company and the names of the third parties to whom it has been disclosed. However, the right of access is not absolute and access may be refused in accordance with applicable law. Associates/Contractors may request that errors or omissions in their Personal Information be corrected or rectified and if the Company is satisfied on reasonable grounds that the request should be implemented, it will correct/supplement the information as soon as reasonably possible and send the corrected information to each organization to which the original Personal Information was disclosed.  However, if the Company is not satisfied that the request should be implemented, it will annotate the information, noting the requested correction that was not made. You may also have the right to withdraw your consent, subject to legal and contractual restrictions.

Duties

Associates/Contractors should keep their Personal Information as up to date and accurate as possible.  Associates/Contractors shall notify the Human Resource representative or their manager as soon as possible of any changes in their Personal Information such as marital status, contact information, dependent/beneficiary information, etc.

Electronic Monitoring   

For purposes of this Disclosure, "Electronic Monitoring" means the Company’s collection of information about an Associate/Contractor’s activities, through means such as Company-owned electronic devices and Associate/Contractor-owned electronic devices that are used for work purposes wherever work is performed (including remote work locations), such as computers, computer networks, cell phones, video cameras, dashboard monitoring devices, and GPS units (“Work Devices”).

Associates/Contractors should have no expectation of privacy when using Company-owned technology or vehicles or whenever accessing Company-owned networks, technology resources or information.  Associates/Contractors should have no expectation of privacy when operating vehicles that are not owned by UNFI, but in which a UNFI-owned electronic monitoring device has been installed.

Electronic Monitoring is generally conducted to ensure the safety and security of Associates/Contractors, facilities and property and to comply with legal obligations.  The Company may engage in legitimate and reasonable Electronic Monitoring of Associates/Contractors with the Associate/Contractors consent, and/or when it has reasonable grounds to believe that their use of Work Devices:

• Does not comply with law, this Privacy Disclosure or other applicable Company policies and guidance;
• Can cause damages to the reputation, the business activity, the facilities, vehicles, property, or the intellectual capital of the Company;
• Contravenes to their employment or contractor contract; and/or
• Poses a security risk to the confidentiality, integrity, and accessibility of any information stored or communicated via Company.

Examples of and reasons for such Electronic Monitoring are more fully described in Schedule 2, below.

The Company may store copies of data and communications acquired through Electronic Monitoring after they are created and may delete such copies from time to time without notice in accordance with its retention schedule and applicable law.  The Company will maintain and revise this Privacy Disclosure as required to ensure it reflects our current electronic monitoring practices.

Updates to the Privacy Disclosure

This Privacy Disclosure is subject to occasional revision, and if we make any material changes in the categories of information we collect or the reasons we collect that information, we will notify you by sending you an e-mail and/or by prominently posting notice of the changes.  Where required by applicable law, we will obtain your express consent for new purposes of processing your Personal Information.  This Privacy Disclosure will also be posted to The Sweet Spot under Policies/Legal for you to review or consult at any time. 

The Company may be subject to certain laws and regulations relating to privacy and information security in more than one jurisdiction in which Associates/Contractors reside.  If any term, covenant, condition, or provision of this Privacy Disclosure is held by a court of competent jurisdiction to be invalid, void, or unenforceable, it is the intent of this Privacy Disclosure that the scope of the rights and obligations of the Privacy Disclosure be reduced only for the affected jurisdiction and only to the extent deemed necessary under the laws of the local jurisdiction to render the provision reasonable and enforceable and the remainder of the provisions of the Privacy Disclosure will in no way be affected, impaired, or invalidated as a result.

Consent

As the Personal Information collected, used, and disclosed by the Company is necessary to establish and maintain an employment or contractor relationship, the consent of Associates/Contractors to this collection, use and disclosure is, in most cases, a condition of employment. For example, the use of Electronic Monitoring through external-facing vehicle dashboard cameras is a condition of employment or service relationship for Associates/Contractors who operate Company-owned vehicles or when operating vehicles not owned by UNFI, but in which a UNFI-owned electronic monitoring device has been installed.  Thus, if the Associate/Contractor doesn’t consent to the collection, use or disclosure of a particular type of Personal Information, they must contact the Chief Privacy Officer.

Quebec Residents

This section of the Privacy Disclosure only applies to residents of Quebec.  You may have the right to withdraw consent related to the Personal Information we collect about you, subject to where consent is a condition of the Associate/Contractor relationship.  Certain Electronic Monitoring may constitute “profiling” under applicable law such as vehicle external monitoring cameras.  Company may remotely activate the functions that constitute “profiling” at any time after the installation of such technology.  The purposes for which Company processes your Personal Information in this way are described in Schedule 2, below.  Company may disclose your Personal Information with service providers of Electronic Monitoring technology who may be located outside of Quebec.  If you have questions regarding the scope of your consent to Electronic Monitoring, please use the contact information listed in the following section of this Privacy Disclosure.

Contact us with Questions

If you have questions regarding this Privacy Disclosure, please contact the Chief Privacy Officer Kim Myrdahl, who is the person in charge of the protection of Personal Information, at 952-828-4159, or by visiting https://www.unfi.com/privacy/inquiry.html.  You may also contact the Ethics and Compliance Office at ethics.compliance@unfi.com or 952-828-4230.

 

Schedule 1

Categories of Data and Examples of the Data That May Be Collected

 

Categories of Personal Information	Examples of Data that May Be Collected	Reasons for Collection, Use and  Disclosure
A. General     Some Personal Information included in this category may overlap with other categories below	Legal name, signature, aliases Postal address, telephone number, education, employment, employment history Bank account number, group insurance policy number, credit card number, debit card number, or any other financial information Unique personal identifier, online identifier assigned by the Company, Internet Protocol address of the Associate’s/Contractor’s computer and/or router, email address, Company account name Social insurance number, driver’s license number, passport number, or other similar identifiers Physical characteristics or description  Medical information, or health insurance information	Provide Benefits Facilitate the purchase of products by Associates/Contractors from the Company Administer group insurance plans Expense reimbursement Monitor Associates’/Contractors’ use of Company’s computers, systems and equipment in accordance with Company’s acceptable use policies Ensure that Associates/Contractors driving Company vehicles are licensed Make international travel arrangements for Associates/Contractors travelling on Company business Ensure the Safety of Associates, Contractors, Facilities, and Property - i.e., to ensure that only authorized personnel are present at Company facilities and only authorized personnel are operating Company vehicles/equipment
B. Sensitive Personal Information	Age, race, ethnicity, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation For Quebec residents only, any information, in particular medical information (and biometric information as described below), due to its nature or the context of its use or communication, entails a high level of reasonable expectation of privacy.	Administer the Associate/Contractor Relationship Comply with Legal Obligations Proactively plan for accommodations Facilitate Communications and Efficiency Facilitate Company’s inclusion and diversity program Provide Benefits, including parental benefits Qualify Associates/Contractors for available reductions in benefits costs Monitor health of Associate’s/Contractor’s for infectious diseases at the Company’s food-handling facilities Ensure the Safety of Associates, Contractors, Facilities, and Property – i.e., to ensure that Associates/Contractors are treated in accordance with human rights legislation and the Company’s inclusion and diversity program
C. Commercial Information	Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	Facilitate Communications and Efficiency Provide Benefits such as ability to purchase products from Company
D. Biometric Information	May include fingerprints, or other physical patterns, and sleep, health or exercise data.	Administer the Associate/Contractor Relationship, including timekeeping Identification and fraud prevention Provide Benefits Ensure the Safety of Associates, Contractors, Facilities, and Property to ensure that only authorized personnel are present at Company facilities or operating Company vehicles/equipment
E. Internet or other similar network activity	Browsing history, search history, information of an Associate/Contractor’s interaction with a website, application, or advertisement.	Monitor Associates’/Contractors’ use of Company’s computers, systems and equipment in accordance with Company’s acceptable use policies Facilitate Communications and Efficiency Provide Benefits such as purchases from the Company or facilitate use of benefit providers’ websites
F. Geolocation data	Physical location or movements.	Facilitate Communications and Efficiency Provide Benefits Ensure the Safety of Associates, Contractors, Facilities, and Property Tracking location of Company assets such as vehicles Ensure that only authorized personnel are present at Company facilities or operating Company vehicles/equipment Monitor vehicle driving habits to ensure safe driving and record potential vehicle incidents or theft
G. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	Administer the Associate/Contractor Relationship Comply with Legal Obligations Facilitate Communications and Efficiency Provide Benefits Ensure the Safety of Associates, Contractors, Facilities, and Property Monitor health of Associates and Contractors for infectious diseases at the Company’s food-handling facilities
H. Professional or employment-related information	Current or past job history or performance evaluations.	Administer the Associate/Contractor Relationship Comply with Legal Obligations Ensure the Safety of Associates, Contractors, Facilities, and Property

 

Schedule 2

Examples of and Reasons for Electronic Monitoring

Examples of Electronic Monitoring	Reasons for Electronic Monitoring
Recording and/or reviewing telephone conversations and transmissions (including review of voicemail), electronic mail and transmissions, internet access and usage by an Associate/Contractor through any electronic device or system, including the use of a computer, telephone, wire, radio or electromagnetic, photoelectronic or photo-optical systems	Protecting the integrity of Company’s IT and communications systems, including protection against computer viruses, damage to software or hardware, loss of Company’s documents or information and protecting against excessive internet usage Protecting against unauthorized access or disclosure of Company’s confidential information, proprietary information, or Associate/Contractor or third-party Personal Information in Company’s control Monitoring the use of internet access, including access to social media sites, to ensure that use is in accordance with Company guidelines and policies Monitoring Associate/Contractor access to Company-owned social media resources to ensure compliance with Company guidelines and policies. Finding lost messages or data, or to retrieve messages lost due to computer failure Managing the type or volume of incoming or outgoing electronic mail or telephone voice mail or internet usage Computer system maintenance and/or protection Assisting in investigations of alleged wrongdoing or violations of Company policies Complying with any other legal obligations Facilitating customer care
Video surveillance of Associate/Contractor work areas	Ensuring the Safety of Associates, Contractors, Facilities and Property Protecting Associates/Contractors against discriminatory, harassing, or violent behaviour from co-workers or third parties Preventing theft
Recording and/or reviewing Associate/Contractor usage of business equipment including, but not limited to, telephones, computers, photocopiers, fax machines, and printers; reviewing computer files handled by an Associate/Contractor	Protecting the integrity of Company’s IT and communications systems. This includes protection against computer viruses, damage to software or hardware, loss of Company’s documents or information and protecting against excessive internet usage Protecting against unauthorized access or disclosure of Company’s confidential information, proprietary information, or Associate/Contractor or third-party Personal Information in Company’s control Monitoring the use of internet access, including access to social media sites, to ensure that use is in accordance with Company guidelines and policies Monitoring Associate/Contractor access to Company-owned social media resources to ensure compliance with Company guidelines and policies Finding lost messages or data, or to retrieve messages lost due to computer failure Computer system maintenance and/or protection Assisting in investigations of alleged wrongdoing or violations of Company guidelines and policies Complying with any other legal obligations Monitoring productivity and achievement of incentives
Recording and/or reviewing Associate/Contractor entrance and exit from Company premises through the use of electronic card swiping devices, biometric recording devices or other means	Tracking number of hours worked Protecting Associates/Contractors against discriminatory, harassing or violent behaviour from co-workers or third parties Preventing theft Understanding who is on Company premises in the event of an emergency
Reviewing Associate/Contractor travel and entertainment expenses	Ensuring compliance with Company guidelines and policies Preventing theft and other wrongdoing Complying with any other legal obligations
Monitoring activities of Company owned or leased vehicles through use of GPS, road-facing video cameras and similar tracking devices	Ensuring the safety of drivers Ensuring compliance with Company guidelines and policies Tracking deliveries Complying with any other legal obligations Locating and safeguarding Company property