91ĘÓƵ

purpose OF THIS NOTICE: In this Privacy Notice (the “Notice”), we describe the information that we collect from our employees (current, former, part-time) who are California residents (an “Employee”).  This Notice is intended to satisfy our applicable notice requirements under the California Consumer Privacy Act (“CCPA”).  In this Notice, we only describe the information required to be discslosed under the CCPA; we may provide you additional notices about other data collections, if applicable (e.g., background checks).

SCOPE OF THIS NOTICE: This Notice applies to the following personal information that we collect about you: 

 

• Personal information that we collect from and about you during your engagement with us;
• Emergency contact information that we collect and use for emergency contact purposes
• Other personal information that we collect related to our administration of benefits

 

What is personal information? In this Notice, “personal information” is 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 California resident or household. 

Are our practices the same for all Employees?  The categories of personal information we collect and use may vary depending upon the circumstances, such as your role and responsibilities with us. This Notice provides an overall description about how we collect and use your personal information. 

Categories of Personal Information Collected: Generally, we may collect the following categories of personal information about you: 

• Name, Contact Info and other Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier, email address, phone number, account name, social security number, driver’s license number, passport number, or other similar identifiers.  
• Protected Classifications: characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information.
• Usage Data: internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a resident’s interaction with an internet website, application or advertisement, as well as physical and network access logs and other network activity information related to your use of any company device, network or other information resource.
• Geolocation Data: precise geographic location information about a particular individual or device.
• Audio/Visual Data: audio, electronic, visual, thermal, or similar information. We capture this information through our premises that use CCTV and/or if you make a call into a recorded line and/or answer phones at our call center.
• Employment History: professional or employment-related information.
• Education 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).
• Profiles and Inferences: inferences drawn from any of the information identified above to create a profile about a resident reflecting the resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
• Biometric Information: information that may be defined as biometric information, such as fingerprints and facial scans.
• Additional Information: At this time, we may be collecting the following additional information from you: temperature; recent travel and exposure to persons who might have traveled; a diagnosis, or potential diagnosis of COVID-19; and other information relevant to protecting you and the workforce related to the threat of COVID-19, such as whether you have been vaccinated.

Purposes for collecting and using personal information: Generally, we may use the above categories of personal information for the following purposes:

• Compensation and Benefits Administration.  Relating to our administration of compensation and benefits, including:
  • Administering employee payroll, salary and compensation
  • Calculating deductions, issuing tax return-related documents and forms to employees
  • Administering employee pensions, IRAs and 401K, health insurance, medical plans and other employee benefits administration (which may include collecting personal information about others, such as beneficiaries, where necessary to administer such benefits)
  • Reviewing, assessing and administering employee salary and compensation and bonuses
  • Reviewing timecards and reported time worked
  • Monitoring and managing PTO, holiday, FMLA and other leaves of absences 
• Management of Working Relationship. To manage our relationship with you, including:
  • Hiring, terminations, relocation, transfers, promotions and disciplinary actions  
  • Notifying you about employment opportunities related to your current role
  • Reviewing performance
  • Employee compensation and bonus reviews, and headcount and salary reviews
  • Administering and monitoring compliance with our policies and procedures
  • Administering procedures related to employee attendance and timekeeping
  • Maintaining records of emergency contact information for use in an emergency
  • Administering or performing employment contracts where applicable
  • Conducting employment screening
  • For professional development and training purposes
  • Verifying and managing applicable credentials, licensing and other qualifications  
  • Facilitating employee communication and collaboration, such as through the corporate directory, employee bios and other similar channels
  • Supporting our equal opportunity employment policy and diversity and inclusion program
• Conducting Business and Management of Client Relationships. Relating to the organization and operation of our business and our performance of services to clients, including:
  • Operating our business by developing, producing, marketing, selling and providing goods and services
  • Providing after-sales services to clients
  • Auditing and assessing performance of business operations, including client services and associated activities
  • Training and quality control  
  • Satisfying client reporting and auditing obligations
  • Facilitating business development opportunities, as relevant
  • Facilitating communications in furtherance of the foregoing
• Security and Monitoring. To monitor and secure our resources, network, premises and assets, including:
  • Monitoring for, preventing and investigating suspected or alleged misconduct or violations of work rules
  • Monitoring for, preventing, investigating, and responding to security and privacy incidents
  • Providing and managing access to physical and technical access controls
  • Monitoring activities, access and use to ensure the security and functioning of our systems and assets
  • Securing our offices, premises and physical assets, including through the use of electronic access systems and video monitoring.
• Auditing, reporting corporate governance and internal operations.  Relating to financial, tax and accounting audits, and audits and assessments of our business operations, security controls, financial controls, or compliance with legal obligations and for other internal business purposes such as administering our records retention program.
• M&A and Other Business Transactions.  For purposes of planning, due diligence and implementation of commercial transactions, such as mergers, acquisitions, asset sales or transfers, bankruptcy or reorganization or other similar business transactions. 
• Defending and Protecting Rights. 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, or the rights, interests, health or safety of others, including in the context of anticipated or actual litigation with third parties.
• Compliance with Applicable Legal Obligations. Relating to compliance with applicable legal obligations (such as hiring eligibility, 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.
• Health and Safety.  We collect your temperature, travel history, and COVID-19 diagnosis for the health and safety of our workforce and the premises on which are workforce is staffed. We also will use this information to help us determine where there is a need for a change in or additional staffing. If you inform us that you have tested positive for COVID-19, we also may use that information to contact persons with whom you might have had contact.

 

CONTACTING US ABOUT THIS NOTICE:  If you have any questions or concerns regarding our use of personal information as described in this Notice, please contact your Human Resources Director or the 91ĘÓƵ Hotline at .