Workforce Privacy Policy

Workforce Privacy Policy PDF

Thrivent is committed to safeguarding the information we collect. Information we gather is shared only with outside organizations that are performing services for us or on our behalf, or as permitted by law. Please review this Policy to help you better understand our views and practices regarding the collection, protection, sharing, and use of information collected as part of one or more workforce processes.

Scope

This Workforce Privacy Policy is being provided by Thrivent and select affiliates, referred to in this Policy as "Thrivent". The information provided here applies to individuals who are seeking employment, have been hired, or were previously a member of Thrivent's workforce, including spouses/domestic partner and dependents of current or former workforce members, when spouse/domestic partner and dependent information is necessary to complete an employment process. For purposes of this Policy only, "workforce" and "employment" includes the above identified individuals and groups, individuals who are serving on a Thrivent Board of Directors, as well as individuals who are performing services for Thrivent in a contractor role, such as captive or independent agents.

For all other consumers, you can review our privacy practices by accessing our consumer Privacy Policy. If you have a previous or existing business relationship with Thrivent, you would be considered a customer, and information about the privacy of your information can be found in our Customer Privacy Notices.

Personal Information

How is Personal Information collected, used, and shared?

Thrivent may collect Personal Information (information that can be used to identify you as an individual) through various methods.

Below are some specific scenarios regarding personal information we collect as part of the employment relationship, who we may collect it from, the purpose of collection, and the categories of entities we may share that information with.

For all categories of information discussed below, information is only shared with:

• Our service providers: In order to fulfill your request or to complete an operational function for Thrivent, such as administering benefits.
• Government agencies and regulators: In order to demonstrate Thrivent's compliance with various laws and regulations.
• Legal Proceeding or Action: Information may be shared as required by a legal proceeding, litigation or subpoena.

Identifiers

For all employment types, we will collect your name, address, email address, phone number and social security number. In general, this is to ensure that we have the correct information to contact you, to verify your employment eligibility, or to provide you access to Thrivent systems, such as Workday on thrivent.com or our independent producer hub. We may also collect the following identifying information:

• Dependent information, we utilize this information to administer Thrivent-sponsored benefits.
• Thrivent ID: Upon hire, members of the internal workforce are assigned a Thrivent identification number. This number will be used to authenticate your access to Thrivent technology as well as to track your interactions with various Thrivent applications and webpages.

Basic identifying information, such as name and contact information, may be shared for marketing purposes, with any client preferences being honored, as applicable.

Protected classifications

Thrivent is an Equal Opportunity Employer. While we may collect personal information related to protected classes, such as race, age, sex, or ethnicity, please rest assured that this information is collected and used only to fulfill legal requirements, such as reporting on the demographic makeup of our workforce, to complete background checks, verify citizenship status, or to determine eligibility for certain benefits.

We may also request information regarding your religious affiliation, such as church congregation, for certain positions on one or more of our Board of Directors. This information is necessary to ensure that we are meeting criteria necessary to retain our status as fraternal benefit society.

Commercial information More Information

Information related to your commercial affairs may be requested or collected to ensure compliance with Thrivent policy or regulatory obligations. Some examples may include:

• Expense reimbursement: We will request itemized receipts of your purchases.
• Investment practices: Trade practices of "supervised" and "access" persons are monitored to ensure that they do not violate antifraud rules, such as insider trading.
• Background checks: This process may reveal information related to previous bankruptcy filings or financial fraud incidents. This information may be used to exclude or limit your ability to perform certain roles based on laws and regulations.
• Adoption assistance: Reimbursement under our Adoption Assistance benefit will necessitate itemized receipts to prove that expenses were made for qualifying purpose.

Biometric information

Biometric information may be collected and shared in order to comply with specific legal requirements, such as when finger prints are collected and provided to the FBI and FINRA in order to complete required background check requirements.

Certain applications that you have access as part of your employment relationship with Thrivent allow for use biometrics of for more expedited authentication. Thrivent does not currently collect the biometric information in these cases.

Internet or Electronic Network Activity More Information

When you apply for a position at Thrivent we ask if you would like to provide us with a link to your LinkedIn profile. It is not required that you do so. This information is reviewed for additional hiring criteria only. This information is not shared.

Audio, electronic, visual, thermal, or olfactory information

Thrivent only collects audio information in the form of call recordings. While Thrivent will not record calls for employment-related inquiries, if you work in one of our client call centers or you interact with a call center as part of your job duties, your voice will be recorded as part of any transaction. Voice recordings are not shared, except by legal request.

Thrivent also uses silent monitoring techniques to monitor its workforce. All activities conducted while on premises or while using Thrivent equipment are subject to monitoring for quality assurance, to protect the company, to conduct investigations, and to avoid liability.

Professional or Employment information

When you apply for any job with Thrivent, we will request that you provide details about your previous employment, including any licenses or training to perform specific roles. This information is necessary so that we can validate that you have the necessary experience and credentials to perform the role. In addition, professional information may be collected in the following scenarios:

• Licensed persons: If you have one or more security licenses, we will request that you provide information to us about your involvement with other business entities. We will need to understand your role and the nature of the business to ensure that we, and in effect you, are in compliance with Outside Business Activity laws.
• Background checks: As part of your application, we may inquire about any previous misconduct in a professional setting. In addition, Thrivent, through a third party, may conduct a background check on prospective workforce members and periodic checks on current workforce members. This process will gather information about you, including professional/ employment information, from multiple sources. This information may be used to exclude or limit your ability to perform certain roles based on risk and compliance considerations.
• Military service: If you request to take a leave from your employment with Thrivent to fulfill military service orders, we will request to obtain details regarding your orders for documentation purposes.

Education Information

When you apply for any position with Thrivent, we will request that you provide details about your education, such as name of any educational institutions you attended, the location, years attended, and degrees obtained. This is so that we can validate that you have the necessary educational qualifications to perform the job responsibilities. Below is an example of when we may collect additional information related to your education.

• Tuition assistance: If you are eligible, and request to take advantage of our tuition assistance program, we will collect information from you regarding your enrollment, degree progress, and transcripts to ensure that you're in compliance with tuition assistance policy.

Other categories of Personal Information More Information

There are other types of personal information that Thrivent may collect during the course of any employment relationship, including:

• Signatures: Thrivent may collect a digital or wet signature on various forms required to be gathered as part of the onboarding process.
• Bank account numbers: Thrivent requires that you provide bank routing and account numbers for direct deposit of your paycheck or expense reimbursement.
• Medical/Health information: This information is collected from, or about, you only if such information is relevant because of a circumstance related to your health consistent with applicable laws including the Family and Medical Leave Act, Americans with Disabilities Act, and workers' compensation statutes. The specific pieces of information collected and the detail necessary varies depending on the circumstances.

Exclusions:

• While Thrivent does provide employer-sponsored health, life, and disability insurance, Thrivent does not receive any identifiable health information regarding workforce, spouse/domestic partner, or dependent medical care or payment for care.

Inferences drawn to create a profile

We may collect any or all the information above in order to create an employment profile for you. This may include your preferences, aptitudes, abilities, attitudes, or behaviors that we can determine from the information you provide and/or your background check results. We collect this information so that we can ensure that we have individuals in the roles that best align with their skills and we, as an employer, can assure our regulators that those members of our workforce who represent Thrivent have the necessary skills, training, and values.

How can you update your personal information through Workday?

By accessing your Workday profile, you can update your professional and contact information, such as resume, address, email address, and phone number. You may also update other information retained in your Workday profile, such as dependents, beneficiaries, or benefits elections, however some of these actions may require additional validation by Thrivent before changes can become effective.

How can you update your personal information without Workday access?

For all workforce members, it is important that you keep your contact information current. Even post-termination, it is important to keep your contact information current so that Thrivent can appropriately administer any benefits that you are entitled to.

If you do not have access to make changes to your personal information via Workday, you can contact the Thrivent Human Resources Helpline:

Internal: 628-6414 or 844-6414
External: 1-800-847-4836, say the word "Directory" and enter extension 6414 when prompted.
Email: human.resources@thrivent.com

How do we secure the information we collect?

Thrivent has standards of security to protect your data by putting in place physical, technical and administrative safeguards. The technology we use to protect your data is reviewed and improvements are implemented as needed.

Authorized employees and representatives are permitted to access and use data about you for approved business purposes. All members of our workforce must complete all required training to ensure they understand and follow established policies and laws when using your data.

Your information may be accessible by third party vendors for the purpose of enabling them to store such data in connection with the permitted uses of your information under this Privacy Policy. Our third-party providers have an obligation to maintain the confidentiality of the information, except where disclosure is required by law.

Questions or Comments?

If you have questions regarding this Workforce Privacy Policy, please call the Thrivent Privacy Office at 920-628-2359, or email us at Privacy@Thrivent.com.

You can also send a written inquiry to:

Thrivent
Attn: Privacy Office
4321 N. Ballard Rd.
Appleton, WI 54919