Global Employee & Candidate Privacy Policy
At Coalition, your privacy is a priority. We are committed to being transparent about how we collect, use, and protect the personal data of our prospective, current, and former employees.
This Policy explains how we handle your personal information in connection with your application for employment or your ongoing professional relationship with us.
The defined terms in this Policy have the following meanings:
“Candidate” means an individual who has submitted information to Coalition in order to become a Workforce Member, or who has otherwise provided consent to be considered as a candidate for employment with Coalition.
“Workforce Member” means a full or part time Coalition employee, director, board member, non-executive director, independent contractor, interns or agency workers.
What Personal Data Do We Collect and How Do We Get It?
Depending on whether you are a Candidate or Workforce Member, we may collect the following categories of personal data about you to the extent permitted under local law. Some may or may not apply to you.
Data Category | Examples |
Identification Data | Name, Photograph, Date of Birth, Government Identifiers, Employee Identification Number |
Contact Information | Residential Address, Telephone, Email Addresses, Emergency Contact Information |
Hiring Data | Information Relating to Candidate Qualifications, Past Employment, Interview Notes, References, Immigration Status & Documentation, Residency Permits & Visas |
Demographic Data | Date of Birth, Gender, Race/Ethnicity, Veteran Status, Disability, Sexual Orientation, Gender Expression, Marital Status, Dependent Status |
Financial Data | Banking Details, Tax Information, Payroll Information, Withholdings, Salary, Expenses, Company Allowances, Stock & Equity Grants |
Performance & Management Data | Information related to performance evaluations or reviews, disciplinary actions & grievances, & training & development plans |
Internet or Other Similar Network Activity Information | Activity on Coalition’s information systems (such as internet browsing history, search history, intranet activity, email communications, stored documents and emails, usernames and passwords) and all activity on communications systems (such as phone calls, call logs, voicemails, text messages, chat logs, app use, mobile browsing and search history, mobile email communications and other information regarding an employee’s use of Coalition-issued devices) |
Benefits Data | Information related to employee benefits we provide to you, such as spouse and dependent information, health information (including vaccination status), vacation, leaves of absence, & accommodations information, pensions contributions (including amounts paid, the frequency and currency of payment) |
Employment Data | Information related to your qualifications, your role at Coalition such as position information, role changes, resignation/termination, resume/CV, employment contracts, office location, academic/professional qualifications, criminal records data, immigration status & documentation, residency permits & visas, national ID/passport, occupational health assessments & work-related accidents, training & employee resource group participation |
Other Information You Might Share with Us | Information you choose to provide to us, including social preferences, feedback surveys, and participation in other company-sponsored programs |
What are the Legal Bases for Processing Personal Information?
The following legal bases apply to the processing activities conducted during recruitment and throughout the term of employment.
Processing Activity | Types of Personal Data Processed | Legal Basis for Processing |
Recruitment — Creation of a job applicant file — Managing job applications — Organizing interviews | — Identification Data — Contact Information — Hiring Data — Demographic Data — Employment Data | Legal obligations, and legitimate interests (to enable us to effectively recruit staff). For any sensitive personal data processed (such as health data or data concerning racial or ethnic origins), we may also rely on employment legal obligations. |
Selection — Conducting background checks — Onboarding
| — Identification Data — Contact Information — Hiring Data — Demographic Data — Employment Data | Legal obligations, and legitimate interests (to enable us to effectively recruit staff). For any sensitive personal data processed (such as health data or data concerning racial or ethnic origins), we may also rely on employment legal obligations. |
Managing staff relations — Creation and updating of training and other development opportunities — Determination of work performance requirements and career development needs — Arranging and/or reimbursing travel — Management of day-to-day business operations (managing inter-business relationships) — The creation of employee directories or to send documents or other items to your residential address — Investigate and support decisions on disciplinary actions or terminations, conduct grievance management, or as necessary to detect fraud and other wrongdoings | — Performance & Management Data | Contract performance, legal obligations, and legitimate interests (to enable us to manage our staff). For any sensitive personal data processed (such as health data or data concerning racial or ethnic origins), we may also rely on employment legal obligations. |
Storage of Workforce Member related emails and Workforce Member related documents | — Internet or Other Similar Network Activity Information | Legitimate interests (to enable us to effectively manage our staff and our staff's output). For any sensitive personal data processed, we may also rely on employment legal obligations. |
Security purposes — To maintain the security of Coalition’s computing resources, assets and premises, and provide you with access to them, to manage our general operations and assets, and to provide services to you as necessary for your role; — Prevent unauthorized access to, use, or disclosure or removal of Coalition’s property, records, data, and information
| — Internet or Other Similar Network Activity Information | Legitimate interests (to enable us to ensure the security of our systems). |
Employee benefits — Management of payroll, taxes and benefits, as well as work-related claims and leaves of absence | — Contact Information — Benefits Data | Contract performance, legal obligations, legitimate interests (to enable us to provide you with your remuneration and benefits). For any sensitive personal data processed, we may also rely on employment legal obligations, protection of vital interests of you or another person (where you are unable to consent), health services or legal claims. |
Occupational health and absences — Establishment of emergency contacts for you and respond to and manage emergencies, crises, and business continuity | — Contact Information — Demographic Data — Employment Data | Legal obligations, and legitimate interests (to enable us to effectively manage our employees’ fitness for work). For any sensitive personal data processed, we may also rely on employment legal obligations, protection of vital interests of you or another person (where you are unable to consent). |
Workforce management — DEI goals (e.g., understanding the diversity of our workforce and support core business diversity, equity, and inclusion initiatives) | — Demographic Data — Other Information You Might Share with Us | Legitimate interest (to enable us to effectively manage our workforce). For any sensitive personal data processed, on the basis of consent. |
Compliance with law and regulations — Fulfilling external obligations, including reporting responsibilities (e.g., labor and employment laws, health and safety, tax, anti-discrimination laws) or to exercise or defend our legal rights | — Identification Data — Contact Information — Hiring Data — Demographic Data — Financial Data — Performance & Management Data — Internet or Other Similar Network Activity Information — Benefits Data — Employment Data | Legal obligations, legal claims, legitimate interests (to enable us to cooperate with law enforcement and regulatory authorities). For any sensitive personal data processed, we may rely on legal claims and substantial public interest (prevention and detection of fraud and crime). |
What Personal Information is Shared with or Obtained from Third Parties?
You provide us with most of your persoal information. However, we may also obtain personal information about you from third parties such as recruiting agencies.
We share your personal information within Coalition only when necessary for legitimate business purposes and in compliance with applicable laws. Following a comprehensive vetting process, we may disclose your information to the following categories of third parties:
HR service providers (e.g., benefits providers, payroll providers);
Insurance organizations;
External advisors, such as legal counsel, management consultants, and accountants, including in the event of a business sale or transfer;
Employee benefits providers; and
Government organizations or agencies.
Coalition does not sell your personal information. For a full list of subprocessors and their jurisdictional location, please visit our subprocessor list.
How Long is Your Personal Information Retained?
Your personal information is retained only for so long as permitted by applicable privacy laws. For a complete list of retention limits, please contact us at privacy@coalitioninc.com.
How is Personal Information Transferred Outside of my Jurisdiction?
Coalition has users located across the globe. We are headquartered in the United States with service providers that operate in other countries. We may transfer your personal information to the United States and other countries which may not have the same data protection laws as your home country or territory and may, in some instances, require disclosure to law enforcement authorities. Coalition relies on Standard Contractual Clauses (SCCs) for transfers of personal information outside of the European Union and the United Kingdom. For more information about our policies and practices regarding service providers outside of your home country or territory, please contact us at privacy@coalitioninc.com.
Your Global Privacy Rights
In accordance with applicable global privacy laws, Coalition provides a baseline of privacy rights designed to give you control over your personal information. Depending on your jurisdiction (such as the UK, EU, California, Canada, or Australia), you may have the following legal rights regarding your personal information:
The Right to Access: You may request a copy of the personal information we hold about you, including your personnel file or recruitment records.
The Right to Rectification: If your personal information is inaccurate or incomplete (e.g., a change of address or an error in your employment history), you have the right to request an update.
The Right to Erasure ("Right to be Forgotten"): You may request that we delete your personal information when it is no longer necessary for the purpose it was collected, subject to our legal obligations to retain certain records (such as tax or payroll data).
The Right to Portability: You can request that we provide your personal information in a structured, commonly used, and machine-readable format to be transferred to another service provider.
The Right to Withdraw Consent: Where we rely on your consent to process personal information, you may withdraw that consent at any time.
The Right to Object or Restrict: You may object to the processing of your personal information for specific purposes, such as internal marketing or automated decision-making.
How to Exercise Your Rights
To submit a request, please contact our Global Privacy Team via the following channels:
Email: privacy@coalitioninc.com
Complete our Request Form
Response Time: We will respond to all valid requests within 30 days. If your request is complex or governed by specific local laws (like the GDPR or CPRA), we will notify you if an extension is required.
Our Non-Discrimination Guarantee: Coalition will never retaliate against an employee or candidate for exercising their privacy rights. Your career progression and application status will remain unaffected by your choice to manage your personal information.
Complaints and Contact Information
Coalition is committed to safeguarding your personal data and ensuring transparent access to our privacy team. If you have any questions about this Policy, wish to exercise any of your statutory data protection rights, or would like to lodge a formal inquiry regarding our data handling practices, please contact our privacy team at privacy@coalitioninc.com or the local corporate affiliate assigned to your region in the Global Privacy Directory below. Coalition will acknowledge receipt of your complaint within thirty (30) days of receiving it. We will investigate the matter and keep you informed of its progress without undue delay. We will also notify you for the final outcome of the investigation without undue delay.
Independent Regulatory Recourse
We appreciate the opportunity to resolve any privacy concerns directly with you. However, you maintain an absolute right to lodge a complaint with a data protection authority, supervisory authority, or independent dispute resolution body in your country or region. Below is the directory of competent regulators for each region in which we operate.
Global Privacy Directory The following comprehensive chart consolidates Coalition's regional corporate contact details alongside their corresponding regulatory fallback authorities.
Jurisdiction | Local Corporate Entities & Contact Details | Regulatory Recourse/Privacy Commissioner |
Australia | Coalition Insurance Solutions Pty Ltd Coalition Incident Response Pty Ltd Level 18, 347 Kent Street Sydney, NSW 2000 Australia privacy@coalitioninc.com | Office of the Australian Information Commissioner (OAIC) Mailing Address: GPO Box 5288, Sydney NSW 2001 Telephone: 1300 363 Email: oaicintake@oaic.gov.au Website: www.oaic.gov.au Australian Financial Complaints Authority (AFCA) Mailing Address: Box 3, Melbourne VIC 3001 Telephone: 1800 931 678 Email: info@afca.org.au Website: https://www.afca.org.au/make-a-complaint |
Canada | Canada Insurance Solutions Canada Inc. 1600-925 West Georgia Street Vancouver BC V6C 3L2 Canada Quebec Office: 1020 Rue Bouvier, Suite 400 Quebec, QC G2K 0K9 Canada privacy@coalitioninc.com Coalition Incident Response Canada Inc. 1600-925 West Georgia Street Vancouver BC V6C 3L2 Canada privacy@coalitioninc.com Coalition Claims Solutions Canada, Inc. 333 Bay Street, Suite 3400 Toronto, ON M5H 2S7 Canada Quebec Office: 1020 Rue Bouvier, Suite 400 Quebec, QC G2K 0K9 Canada Privacy Officer: Cara Thompson privacy@coalitioninc.com | Federal: Office of the Privacy Commissioner of Canada (OPC) Mailing Address: 30 Victoria Street, Gatineau, QC K1A 1H3 Telephone: 1-800-282-1376 (Toll-free) or 819-994-5444 Email: The OPC does not accept official complaints or general inquiries via standard public email for security reasons. Online requests and statutory complaints must be submitted securely through the OPC Online Complaint Form. Website: www.priv.gc.ca Quebec: Commission d'accès à l'information du Québec (CAI) Montréal Office (Main Branch) - Mailing Address: 2045 Stanley Street, Suite 900, Montréal, QC H3A 2V4 Québec City Office - Mailing Address: 525 René-Lévesque Boulevard East, Suite 2.36, Québec, QC G1R 5S9 Telephone: 1-888-528-7741 (Toll-free) or 514-873-4196 (Montréal) Email: renseignements@cai.gouv.qc.ca Website: www.cai.gouv.qc.ca Alberta: Office of the Information and Privacy Commissioner of Alberta (OIPC) Mailing Address: #410, 9925 109 Street NW, Edmonton, AB T5K 2J8 Telephone: 1-888-878-4044 (Toll-free) or 780-422-6860 Email: generalinfo@oipc.ab.ca Website: oipc.ab.ca British Columbia: Office of the Information and Privacy Commissioner for British Columbia (OIPC) Mailing Address: PO Box 9038, Stn. Prov. Govt., Victoria, BC V8W 9A4 Physical Location: 4th Floor, 947 Fort Street, Victoria, BC V8V 3K3 Telephone: 250-387-5629 (For toll-free calling within BC, dial Service BC at 1-800-663-7867 and request a transfer to the number listed). Email: info@oipc.bc.ca (For case filings or complex documentation: commissioner@oipc.bc.ca) Website: www.oipc.bc.ca |
Denmark | Coalition Insurance Solutions GmbH Coalition Incident Response Germany GmbH (Denmark) Business Center Lyngby Lyngby Hovedgade 10C 2800 Lyngby Denmark Data Protection Officer: Cara Thompson privacy@coalitioninc.com | If you want to complain to the Danish Data Protection Agency (“Datatilsynet”), the Datatilsynet recommends that you use this form because it helps them to provide the information they need to process your complaint. However, you are also welcome to complain by contacting them in another way. For instance, you may write to the following postal address, or contact them by telephone or email: Carl Jacobsens Vej 35 2500 Valby Telephoning: +33 19 32 00 Emailing: dt@datatilsynet.dk Website: https://www.datatilsynet.dk/ |
France | Coalition Insurance Solutions GmbH Coalition Incident Response Germany GmbH (France) 58 rue de la Victoire 75009 Paris Data Protection Officer: Cara Thompson privacy@coalitioninc.com | Commission Nationale de l’Informatique et des Libertés (CNIL) Address: 3 Place de Fontenoy TSA 80715 75334 Paris Cedex 07 France Telephone (Main Switchboard): +33 (0)1 53 73 22 22 Website: * French: www.cnil.fr * English Version: www.cnil.fr/en |
Germany | Coalition Insurance Solutions GmbH Coalition Incident Response Germany GmbH Thurn-und-Taxis-Platz 6 D-60313 Frankfurt, Germany Data Protection Officer: privacy@coalitioninc.com | Der Hessische Beauftragte für Datenschutz und Informationsfreiheit Address: Postfach 3163 65021 Wiesbaden Germany Telephone: +49 (0)611 1408-0 Email: poststelle@datenschutz.hessen.de (For secure PGP encrypted emails, their public key can be found on their website). Website: datenschutz.hessen.de Secure Online Form: If you want to submit an inquiry or lodge an official privacy complaint securely without using unencrypted email, you can use their official Hessen Online Contact and Complaint Portal. |
Gibraltar | Coalition Risk Solutions Ltd. Coalition Incident Response UK Ltd. 34-36 Lime Street London UK EC3M 7AT Data Protection Officer: privacy@coalitioninc.com | Gibraltar Regulatory Authority Address: Office of the Data Protection Authority - Information Commissioner, Suite 603 Europort, Gibraltar Telephone: +350 20074636 Email: privacy@gra.gi Website: https://www.gra.gi/ |
The Bailiwick of Guernsey (Crown Dependency) | Coalition Risk Solutions Ltd. Coalition Incident Response UK Ltd. 34-36 Lime Street London UK EC3M 7AT Data Protection Officer: Cara Thompson privacy@coalitioninc.com | Office of the Data Protection Authority Address: The Office of the Data Protection Authority, Block A, Lefebvre Court, Lefebvre Street, St Peter Port, GY1 2JP Telephone: +44 (0) 1481 742074 Email: info@odpa.gg Website: https://www.odpa.gg/ |
Isle of Man (Crown Dependency) | Coalition Risk Solutions Ltd. Coalition Incident Response UK Ltd. 34-36 Lime Street London UK EC3M 7AT Data Protection Officer: Cara Thompson privacy@coalitioninc.com | Isle of Man Information Commissioner Address: Isle of Man Information Commissioner P.O. Box 69, Douglas, Isle of Man, IM99 1EQ Telephone: +44 1624 693260 Email: ask@inforights.im Website: https://www.inforights.im/ |
The Bailiwick of Jersey (Crown Dependency) | Coalition Risk Solutions Ltd. Coalition Incident Response UK Ltd. 34-36 Lime Street London UK EC3M 7AT Data Protection Officer: Cara Thompson privacy@coalitioninc.com | Jersey Office of the Information Commissioner Address: Jersey Office of the Information Commissioner, 2nd Floor 5 Castle Street, St. Helier Jersey JE2 3BT Telephone: +44 1534 716530 Email: enquiries@jerseyoic.org Website: https://jerseyoic.org/ |
Sweden | Coalition Insurance Solutions GmbH Coalition Incident Response Germany GmbH Thurn-und-Taxis-Platz 6 D-60313 Frankfurt, Germany Data Protection Officer: privacy@coalitioninc.com | Swedish Authority for Privacy Protection (“Integritetsskyddsmyndigheten”) Address: Integritetsskyddsmyndighete, Box 8114, 104 20 Stockholm, Sweden Telephone: +46 (0)8 657 61 00 Email: imy@imy.se Website: https://www.imy.se/en/about-us/contact-us/ |
United Kingdom | Coalition Risk Solutions Ltd. Coalition Incident Response UK Ltd. 34-36 Lime Street London UK EC3M 7AT Data Protection Officer: Cara Thompson privacy@coalitioninc.com | Information Commissioner's Office (ICO) Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF,United Kingdom Telephone: 0303 123 1113 Welsh Language Line: 0330 414 6421 Email: casework@ico.org.uk (Note: For specific case filings or general queries where you prefer not to use the webform). Website: www.ico.org.uk Secure Online Complaints: The ICO strongly prefers that data subjects lodge official privacy complaints or record statutory data breaches using their secure guided ICO Complaint Portal. Live Chat: For quick inquiries, the ICO hosts an interactive Live Chat function directly on their main website, which is active Monday through Friday, 9:00 AM to 5:00 PM (UK time). |
United Kingdom | Coalition Insurance Solutions GmbH 34-36 Lime Street London UK EC3M 7AT Data Protection Officer: Cara Thompson privacy@coalitioninc.com | Information Commissioner's Office (ICO) Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF,United Kingdom Telephone: 0303 123 1113 Welsh Language Line: 0330 414 6421 Email: casework@ico.org.uk (Note: For specific case filings or general queries where you prefer not to use the webform). Website: www.ico.org.uk Secure Online Complaints: The ICO strongly prefers that data subjects lodge official privacy complaints or record statutory data breaches using their secure guided ICO Complaint Portal. Live Chat: For quick inquiries, the ICO hosts an interactive Live Chat function directly on their main website, which is active Monday through Friday, 9:00 AM to 5:00 PM (UK time). |
United States | Coalition, Inc. Coalition Incident Response, Inc. Coalition Insurance Solutions, Inc. Coalition Insurance Company Coalition Reinsurance Services, LLC 548 Market St #94729 San Francisco, California 94104-5401 USA privacy@coalitioninc.com | Federal Trade Commission (FTC) Address: 600 Pennsylvania Avenue, NW, Washington, DC 20580 Federal Trade Commission Consumer Response Center Phone: 1-877-FTC-HELP (1-877-382-4357) Websites: Main Agency Site:www.ftc.gov Data Breach/Privacy Complaint Intake: reportfraud.ftc.gov California Privacy Protection Agency (CPPA) Address: 400 R Street, Suite 350, Sacramento, CA 95811 California Privacy Protection Agency (CPPA) - CA.gov Telephone: (916) 572-2900 Website: cppa.ca.gov Secure Complaint Portal: privacy.ca.gov/submit-a-complaint California Department of Justice (Office of the Attorney General) Address: P.O. Box 944255, Sacramento, CA 94244-2550 Telephone: (800) 952-5225 Website: oag.ca.gov/privacy |
Coalition’s Data Protection Officer
You may contact Coalition’s Data Protection Officer (DPO) at privacy@coalitioninc.com.
Changes to this Policy
We may update this policy as necessary to account for changes in our practices or legal requirements.
Contact Us
If you have any questions about this policy or how we process personal information, please contact us at privacy@coalitioninc.com.