California Consumer Privacy
Act Employment Applicant Disclosure
Dear Employment Applicant,
We are committed to the proper
handling of the Personal Information collected or processed in connection with
your application for employment with us. This disclosure describes our privacy
practices with regard to the collection and use of your information and your
choices and rights over your information. The California Consumer Privacy Act
(the CCPA ) defines Personal Information as categories of information that
identifies, relates to, describes or is reasonably capable of being associated
with, or could reasonably be linked, directly or indirectly, to a particular
individual or household.
Information We Collect
Within the last
twelve (12) months, we have collected from our employment applicants and/or employees
the following categories of Personal Information and shared the information
with third party service providers as noted:
|
Category
|
Examples
|
Third
Parties Shared
|
|
A. Identifiers
|
Identifiers, such as name, contact information, online
identifiers and Social Security numbers and other government-issued ID
numbers
|
(a) Human resources information service
providers
(b) Financial investment service providers
(c) Wellness program service providers
(d) Insurance providers
(e) Payroll service providers
(f) Building management/security providers
(g) Professional service providers, including
external auditors
(h) Parties,
courts, mediators, or arbitrators in litigation
|
|
B. California Customer Records
|
Personal information, as defined in the California consumer
records law, such as name, contact information, insurance policy number,
education, employment, employment history, financial information, medical information,
and health information
|
(a) Human resources information service
providers
(b) Financial investment service providers
(c) Wellness program service providers
(d) Insurance providers
(e) Payroll service providers
(f) Building management/security providers
(g) Professional service providers, including
external auditors
|
|
C. Protected Classification Characteristics
|
Characteristics
of protected classifications such as sex, age, race, religion, national
origin, disability, medical conditions and information, citizenship,
immigration status and marital status
|
(a) Human resources information service
providers
(b) Financial investment service providers
(c) Wellness program service providers
(d) Insurance providers
(e) Payroll service providers
(f) Building management/security providers
(g) Professional service providers, including
external auditors
|
|
D. Commercial Information
|
Commercial information, such as transaction information,
purchase history and financial details
|
(a) Human resources information service
providers
(b) Payroll service providers
|
|
E. Biometric Information
|
Facial recognition and fingerprints
|
(a) Building management/security providers
|
|
F. Internet or Other Similar Network Activity
|
Browsing history and interactions with our website, applications,
or systems
|
(a) Analytics and business intelligence vendors
(b) Cybersecurity vendors
|
|
G. Geolocation Data
|
Device location
|
(a) Building management/security providers
|
|
H. Sensory Data
|
Audio, electronic, visual, and similar information, such as
images and audio, video or call recordings created in connection with our
business activities
|
(a) Building management/security providers
|
|
I. Professional or Employment-Related Information
|
Current or past job history
|
(a) Human resources information service
providers
(b) Payroll service providers
|
|
J. Non-public Education Information
|
Grades and transcripts
|
(a) Human resources information service
providers
(b) Payroll service providers
|
|
K. Inferences
|
Profile reflecting a person's preferences, characteristics,
psychological trends, predispositions, behavior, attitudes, intelligence,
abilities, and aptitudes
|
(a) Human resources information service
providers
(b) Payroll service providers
|
|
L. Sensitive Personal Information
|
Personal information that reveals government IDs; racial or
ethnic origin; personal information collected and analyzed concerning a
consumer s health
|
(a) Human resources information service
providers
(b) Financial investment service providers
(c) Wellness program service providers
(d) Insurance providers
(e) Payroll service providers
(f) Building management/security providers
(g) Professional service providers, including
external auditors
|
Personal Information is collected:
1.
Directly from you, such as when you provide it to us
through forms you fill out or communicate with us in any manner.
2.
Indirectly from you, such as observing your
interactions with our computers or systems.
3.
From third parties, such as from background checks.
How We Use Personal Information
Personal Information is collected
for the following purposes:
|
1. To
comply with state and federal law and regulations;
|
|
2. To
process payroll;
|
|
3. To
track time and attendance;
|
|
4. To
manage workers compensation claims;
|
|
5. To
administer and maintain benefits, including group health insurance;
|
|
6. To
administer and maintain retirement service;
|
|
7. To
manage employee performance of their job duties, including promotions,
discipline, and/or termination;
|
|
8. To
conduct workplace investigations;
|
|
9. To
evaluate job applicants and candidates for employment;
|
|
10. To
obtain and verify background checks;
|
|
11. To grant and monitor employees access to
secure company facilities;
|
|
12. To
implement, monitor, and manage electronic security measures on devices that
are used to access networks and systems (e.g., incident management);
|
|
13. To engage in corporate transactions
requiring review of employee records, such as for
evaluating potential
mergers and acquisitions of the Company;
|
|
14. To maintain commercial insurance policies
and coverages, including workers compensation
and other liability
insurance;
|
|
15. To anonymize and/or aggregate data to
perform workforce analytics, data analytics, and
benchmarking;
|
|
16. To perform call monitoring and surveillance
(e.g., CCTV); and
|
|
17. To provide, validate, or communicate
services offered by ADP directly to individuals.
|
Disclosure of Personal Information
We may share your Personal Information
for business purposes by disclosing it to the categories of third parties
identified in the chart above.
We do not sell or share (for
cross-context or targeted behavioral advertising) your Personal Information.
We only use your sensitive
Personal Information for permitted purposes under the CCPA.
Retention Periods
We will generally retain
information about you for so long as we have a legal or business purpose for it
or a legal requirement to maintain it.
The criteria used to determine our retention periods include:
The length of time we have an ongoing
relationship with you (for example, for as long as you are an employee or
prospective employee) and the length of time thereafter during which we may
have a legitimate need to reference your personal information to address issues
that may arise;
Whether there is a legal or ethical obligation
to which we are subject (for example, certain laws require us to keep records
for a certain period of time before we can delete them); or
Whether retention is advisable in light of our
legal position (such as in regard to applicable statutes of limitations,
litigation or regulatory investigations).
Your Rights and Choices
You may have rights regarding
your Personal Information. This section describes the rights you may have and
explains how to exercise those rights.
Access to Specific Information: You may have the right to request
that we disclose certain information to you about our collection and use of
your Personal Information over the past 12 months.
Deletion Request Rights: You may have the right to request that we
delete any of your Personal Information that we collected from you and
retained, subject to certain exceptions.
If an exception applies, we will advise you of the applicable exception
and the reason for denying your request.
Correction Request Rights: You may have the right to request that
we correct any inaccurate Personal Information we may hold about you. We will
use commercially reasonable efforts to correct inaccurate Personal Information,
taking into account the nature of the Personal Information and the purpose for
our processing.
Non-Discrimination: We will not discriminate against you for
exercising any of your rights.
Exercising Your Rights
To exercise any of your rights
described above, please submit a request by:
Sending an email to This email address is being protected from spambots. You need JavaScript enabled to view it., or
Calling us toll free at
(833) 501-0005.
We may need to validate your
request. In order to validate your
request, we may ask you for the following information: your name, dates of
employment, or your department. Only you or an authorized agent may make a request
related to your personal information. To designate an authorized agent to make
a request on your behalf, please provide us with a power of attorney or other
legally binding written document signed by you and identifying your agent. We
may also verify the identity of your designated agent.
Questions About This Privacy Notice
If you have any questions
about the collection and processing of your Personal Information or about the
security of your Personal Information, please contact Human Resources at
858-350-2600 or This email address is being protected from spambots. You need JavaScript enabled to view it..
This disclosure is effective
as of January 1, 2023.
