Special Notice for Collection of Personal Information
Related to the COVID-19 Pandemic (“Special Notice”)
(Effective: July 3, 2020)
This Special Notice applies to Wyndham (“we,” “our”) owners, members, guests, customers, employees, contractors, and any other individuals seeking to gain physical access any of our owned, managed or leased properties or workplaces.
We, or those acting on our behalf under agreement, may collect any or all of the following personal information for public health and safety purposes related to the COVID-19 pandemic: identifiers (e.g., name, address, contact information, social security number, employee ID number); employment-record information, for Wyndham employees or contractors (e.g., job title, department); biometric information (e.g., body temperature, to the extent it is classified as biometric information by local law); protected classifications (e.g., age, gender, medical condition); audio, electronic and visual information (e.g., likeness, video images, voice); and geolocation. In particular, we may collect health-related information (such as body temperature, symptoms, and COVID-19 test results), travel information (including itineraries), information about individuals with whom you recently came into contact, and local location information (such as areas accessed via badge or key swipes).
We will use and disclose this personal information to help maintain a safe environment in our properties and workplaces. Should you report COVID-19 symptoms (as currently identified by relevant health authorities), test positive for COVID-19, or have a body temperature above 37.4 degrees C or the current threshold set by relevant health authorities, or report taking fever-reducing medication, you may be refused entry to the building and/or asked to leave the premises. Your recent travel and contacts may be collected in order to identify and notify individuals who may have been exposed to COVID-19. Your identity will not be shared with any such individuals as part of the notification process.
We may disclose your personal information as permitted by law, including to health authorities and other government or public agencies or officials, for public health and safety purposes in light of the COVID-19 pandemic. If you are a Wyndham employee or contractor, we may also disclose personal information to your supervisor and Human Resources Department, or your employer (if you are not employed by Wyndham), for employment, attendance, and office safety purposes, as well as with third parties assisting in the collection of health-related information.
We will collect this personal information directly from you, from your employment record or our building security logs and cameras, or as part of a pre-arrival questionnaire or an in-person questionnaire or physical exam (e.g., temperature check) which may be conducted by a third party vendor. We will collect this information with your consent, where required by law. To the extent we use third party medical providers, they will provide us with your personal information only with your authorization. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Special Notice unless a different retention period is required or permitted by law.
We will take commercially reasonable steps to de-identify this information where permitted and will retain the information for only as long as necessary given the evolving situation. We will take reasonable steps to protect the information you provide us from loss, misuse and unauthorized access, disclosure, alteration and destruction. We have implemented appropriate physical, electronic and managerial procedures to help safeguard and secure your information from loss, misuse, unauthorized access or disclosure, alteration or destruction. Unfortunately, no security system is 100% secure, thus we cannot ensure the security of all information you provide to us. Please refer to our Privacy Notice on http://www.wyndhamap.com/ or our Privacy Notice on one of our club websites, regarding our general handling of personal information, including your personal information collected pursuant to this Special Notice.
Please note that if your work or travel includes using third-party accommodations, facilities or services, including those of Wyndham’s partners or service providers, these third parties may request any or all of the above personal information or other personal information. Wyndham is not responsible for this personal information. The collection, use, and security of the personal information you provide these third parties is subject to their privacy notices, policies and terms. If you have any questions related to these third parties’ handling of your personal information, please contact them as provided in their privacy notices.
Should you have any questions regarding this Special Notice, please contact your local HR manager (for Wyndham employees) or email@example.com.