Review/Revised: June 2022
Prior to employment, the Company may collect an applicant’s Personal Information for business purposes (both electronically and in hard copy) directly from the applicant, indirectly from the applicant via automated technologies, or from external parties (including publicly available sources). “Personal Information” is information that identifies the applicant, relates to the applicant, or is reasonably capable of being associated with the applicant. The Company may collect Personal Information as identified in Appendix A, attached below.
Personal Information does not include publicly available information from government records, lawfully obtained, truthful information that is a matter of public concern, information that a business has a reasonable basis to believe is lawfully made available to the general public by the applicant or from widely distributed media, or by the applicant, information made available by a person to whom the applicant has disclosed the information if the applicant has not restricted the information to a specific audience, de-identified or aggregated information, or other information specifically exempted by California law (such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and other sector-specific privacy laws (including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the California Financial Information Privacy Act, and the Driver’s Privacy Protection Act of 1994).
The Company uses applicant Personal Information for the following reasons:
- to verify an applicant’s identity for work authorization in compliance with all federal, state, and local laws;
- to verify an applicant’s background and qualifications for his or her position(s);
- to fulfill or meet the reason the applicant provided the information;
- to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
- as described to the applicant when collecting the Personal Information; and
- to provide applicant with access to applicable systems.
Applicant Personal Information is used for the Company’s legitimate business needs only. When we disclose applicant Personal Information to external parties, the parties are bound by contractual obligations to keep the Personal Information confidential and use it only for the purposes for which we disclose it to them. In the preceding twelve (12) month period, we have disclosed applicant Personal Information to the following categories of external parties: our affiliated companies and service providers.
In the preceding twelve (12) month period, we have disclosed Personal Information within the following categories for a business purpose:
- Category A: Identifiers
- Category B: California Customer Records personal information categories
- Category C: Protected classification characteristics under California or federal law
- Category F: Internet or other similar network activity
- Category I: Professional or employment-related information
- Category J: Non-public education information
- Category K: Inferences drawn from other personal information
In the preceding twelve (12) month period, the Company has not sold any Personal Information of applicant to any third parties.
APPENDIX A – Personal Information Collected by the Company
| Category | Examples of Information Under This Category
(*Not all of this information is collected by the Company) |
Whether this Information is Collected and/or Used and the Duration of Retention |
| A. Identifiers | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, government issued identification number, or other similar identifiers.
|
We collect and/or use Personal Information within this category.
Retention Period: For as long as the Company has a business need to maintain/use such information. |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code section 1798.80(e)) | A name, signature, Social Security number, physical characteristics or description, address ,telephone number, government issued identification number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number or any other financial information, medical information or health insurance information. | We collect and/or use Personal Information within this category.
Retention Period: For as long as the Company has a business need to maintain/use such information. |
| C. Protected classification characteristics under California or federal law | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | We collect and/or use Personal Information within this category.
Retention Period: For as long as the Company has a business need to maintain/use such information. |
| D. Commercial information | Records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies. | We do not collect any Personal Information within this category. |
| E. Biometric information | Genetic, physiological, behavioral, and biological characteristics, fingerprints, faceprints and voiceprints, | We collect and/or use Personal Information within this category.
Retention Period: For as long as the Company has a business need to maintain/use such information. |
| F. Internet or other similar network activity | Browsing history, search history, information on a consumer’s interaction with a website, application or advertisement. | We collect and/or use Personal Information within this category.
Retention Period: For as long as the Company has a business need to maintain/use such information. |
| G. Geolocation data | Physical location. | We do not collect any Personal Information within this category. |
| H. Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information. | We collect and/or use Personal Information within this category.
Retention Period: For as long as the Company has a business need to maintain/use such information. |
| I. Professional or employment-related information | Current or past job history. | We collect and/or use Personal Information within this category.
Retention Period: For as long as the Company has a business need to maintain/use such information. |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.W. Section 1232g, 34 C.F.R. Part 99)
|
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | We collect and/or use Personal Information within this category.
Retention Period: For as long as the Company has a business need to maintain/use such information. |
| K. Inferences drawn from other personal information | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | We collect and/or use Personal Information within this category.
Retention Period: For as long as the Company has a business need to maintain/use such information. |
| L. Sensitive Personal Information means certain types of Personal Information, such as: | Social security, driver’s license, state identification card, or passport number, account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, including any data that is derived from a device that is used or intended to be used to locate a consumer within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet, except as prescribed by regulations, racial or ethnic origin, religious or philosophical beliefs, or union membership, the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication, genetic data. | We collect and/or use Personal Information within this category.
Retention Period: For as long as the Company has a business need to maintain/use such information. |