This California Associates and Colleagues Privacy Notice (“Workforce Notice“) describes our information practices relating to our current and former full-time, part-time, and temporary associates, colleagues and staff, as well as Company officers, directors, and owners who are California residents (each an “Associates” “Colleagues“) (collectively the “Workforce” or “you“) who are employees of EmployBridge Holding Company, our affiliates, and subsidiaries (“EmployBridge,” “we,” “our,” “us,” or the “Company“). This Workforce Notice is intended to satisfy the requirements of the California Consumer Privacy Act (as amended by the California Privacy Rights Act of 2020) (collectively “CCPA“).
1. Scope and Relation to Other Policies
This Workforce Notice applies to the Personal Information we collect in the employment context about our Associates and Colleagues. This Policy supplements other Company policies and procedures, including but not limited to, the Employee Handbook, Acceptable Use Policy, and Mobile Device Security Policy. This Workforce Notice applies to any information that identifies, relates to, describes, is reasonably capable of being associated or could reasonably be linked, directly or indirectly, with you (subject to some exemptions under the CCPA) (“Personal Information“).
This Workforce Notice does not address or apply to our information practices that are not subject to the CCPA, such as:
- Business Information. Company or business information that constitutes trade secrets, proprietary information, intellectual property, company property, information that includes or affects the rights of other employees, privileged or investigative materials, or other information that helps ensure security and integrity of company assets.
- Publicly Available Information. Information that is lawfully made available from government records, information we have a reasonable basis to believe is lawfully made available to the general public by you or by widely distributed media, or by a person to whom you have disclosed the information and not restricted it to a specific audience.
- Deidentified Information. Information that is deidentified in accordance with applicable laws.
Aggregated Information. Information that relates to a group from which individual identities have been removed. - Protected Health Information. Information governed by the Health Insurance Portability and Accountability Act or California Confidentiality of Medical Information Act.
- Activities Covered by the Fair Credit Reporting Act. This includes information we receive from consumer reporting agencies that are subject to the Fair Credit Reporting Act e.g., information contained in background check reports we obtain as part of our vetting process.
This Notice also does not apply to the Personal Information we collect from our clients, customers, contractors, job applicants, or our Associates and Colleagues in the context of their personal use of our products and services, which are subject to different notices. For additional information on our general privacy practices, please visit our website Privacy Policy.
We may provide Associates and Colleagues additional notices about our information practices covere by other laws (e.g., background check, drug tests, etc.).
Our information practices may vary depending upon the circumstances, such as your job location, role, and responsibilities with us. Also, in some cases (such as where required by law), we ask for your consent or give you certain choices prior to collecting or using certain Personal Information.
2. Personal Information We Collect
The following identifies the categories and types of Personal Information we may collect about Associates and Colleagues (and may have collected in the last 12 months):
Identifiers. Such as your name, date of birth, address, personal email address, personal phone number, and work contact details (phone, email, and physical address) as well as your dependents’, emergency contacts’, and beneficiaries’ personal identifiers. Additionally, we collect Personal Information such as your social security number, driver’s license or ID number, passport number, or governmental identifiers to verify your identity and authorization to work.
Characteristics of Protected Classifications. Such as your age, gender identity, racial or ethnic origin, disability information, or military or veteran status, if you provide this information as part of your application.
Internet or Other Electric Network Activity Information. Such as browsing history and email usage.
Employment-Related Information. Such as employment history, including job title and position, skills, professional interests, and professional experience so we can place you in a job that you are qualified to do.
Health Insurance Information. Such as your policy number and coverage information if you are eligible for such benefits, make claims, for workers’ compensation, or request disability or leave insurance coverage.
Medical Information. Such as your diagnosis, dates of services, or provider names, when you provide us with information about your ability to work.
Financial Information. Such as bank account information to process payroll.
Geolocation Data. In some circumstances, we may collect information related to your or your device’s geographic location.
Sensitive Personal Information. Such as government-issued identifiers like social security number, driver’s license number, or passport number. To the extent required and voluntarily provided by you, we also may collect information about your race or ethnicity, religion, union membership, and certain financial, medical, or health-related information.
3. Where We Get Your Personal Information
We generally collect Personal Information identified above from the following categories of sources:
- Directly from you
- Recruiters and recruiting platforms
- Former employers (with your prior permission)
- Our service providers, representatives, and agents
- Any references you provide
4. Purposes for Which Personal Information is Collected
We generally collect Personal Information as reasonably necessary for the following business or commercial purposes as permitted by applicable laws:
- To Pay You. To pay you for services performed.
- Manage Our Relationship. To manage our relationship with you, including but not limited to, hiring, relocation, transfers, promotions, performance, disciplinary actions, evaluating potential conflicts of interest, terminations; conducting compensation/headcount/salary reviews; administering and monitoring compliance with our policies, procedures and code of conduct; and maintaining records of emergency contact information.
- To complete necessary paperwork, enroll you in our payroll system, and set up your personnel file.
- To enroll you in eligible benefits; administer employee pensions, IRAs and 401K, health insurance, medical plans, and other employee benefits administration (which may include the collection of Personal Information about others such as beneficiaries, where necessary to administer such benefits); and facilitate business related travelling and business expense reimbursement.
- Leaves of Absence & Accommodation Requests. To manage and respond to requests for leaves of absence, process requests for accommodation, engage in the interactive process, PTO, holiday, FMLA, and other leaves of absences.
- Work-Related Injury, Illness, or Disability reporting. To respond to and process claims if you are injured at work or need a workplace accommodation related to the incident.
Communicate With You. To communicate with you and support inter-Company communication, such as through the Company directory and similar initiatives. - Talent management. For training, performance reviews, succession planning and other employee engagement activities.
- Security and Monitoring. For security purposes to monitor our network activity and safeguard data and assets, which may capture some of your information along with network activity. Please note that EmployBridge reserves the right – but does not assume any obligation – to monitor EmployBridge Computer Systems. Please see Section 7 below for more information about our workplace monitoring policy.
- Business Operations and Client Services. For business purposes such as management of our Information Technology (“IT”) systems and infrastructure, headcount and succession planning, work scheduling, reporting and expense management, quality control and service level verification, and to otherwise support our business operations.
- Auditing, Accounting, Reporting and Corporate Governance. Relating to financial, tax and accounting audits, and audits and assessments of our business operations (including without limitation assessing effectiveness of EmployBridge’s business processes and measuring employee engagement, ensuring business continuity in case of absence or departures from EmployBridge, problem resolution (e.g., internal reviews, grievances), management of whistleblowing channels, internal investigations, auditing, compliance (including conflicts of interest), risk management and security purposes, security controls, financial controls, or compliance with legal obligations and for other internal business purposes such as administering our records retention program.
- Mergers, Acquisitions, and Other Business Transactions. For purposes of planning, due diligence and implementation of commercial transactions, such as mergers, acquisitions, asset sales, transfers, bankruptcy, 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, including without limitation, Public Storage’s trade secrets and other intellectual property, and protecting the rights, property, and reputation of Public Storage and its workforce, or the rights, interests, health or safety of others, including in the context of anticipated or actual litigation with third parties.
- Compliance with Legal Obligations. Related to our compliance with applicable legal obligations (such as determining hiring eligibility or 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.
- Use of Sensitive Personal Information. Our collection, use, and disclosure of sensitive personal information is limited to what is reasonable and proportionate to employ you. For example, complying with our legal, regulatory and reporting obligations.
5. Disclosure of Personal Information
A. Purposes for Disclosing Personal Information
We may disclose the categories of Personal Information we collect for the purposes described above and for the following business purposes.
- Employment Relationship. We may disclose Personal Information when it is necessary to provide services you request and where it is necessary to administer the working relationship.
- Protection of Us and Others. We may disclose Personal Information if required to do so by law, to protect rights, property, or safety of our other associates, workers and contractors, our owners, members, and guests, ourselves or others; or where we have a legitimate interest in doing so.
- Compliance and Legal Obligations. If required to do so by law or subpoena, or if we reasonably believe such action is necessary to comply with the law, judicial proceeding, court order, or the reasonable requests of regulators, law enforcement or other public authorities.
- Corporate Transactions. As we continue to develop our business, we may buy, merge, or partner with other companies, or obtain or extend financings. We may disclose Personal Information as part of those transactions (including in contemplation of such transactions, e.g., due diligence).
B. Categories of Recipients
We may disclose Personal Information to the following categories of recipients:
- Affiliates and Business Partners. We may disclose Personal Information to our affiliates and business partners where necessary to administer the working relationship, conduct our business, or for business operations purposes.
- Service Providers. We may disclose Personal Information to our service providers who perform services on our behalf. Our service providers are required to take appropriate security measures to protect your Personal Information in line with our policies and are not permitted to use Personal Information for their own purposes.
- Benefits Providers. To benefit providers who assist us with administering Associate and Colleague benefits and who help us administer the working relationship and conduct our business.
Regulatory and Government Entities. To comply with our legal obligations and where otherwise required by law, we may disclose Personal Information to applicable regulatory and government entities. - Regulatory and Government Entities. To comply with our legal obligations and where otherwise required by law, we may disclose the following categories of Personal Information to applicable regulatory and government entities: identifiers, characteristics of protected classifications, and employment-related information.
- Clients and Prospective Clients .Clients and prospective clients may request professional and employment-related information for purposes of evaluating an Associate’s credentials, skills and experience. Clients may also need to approve and process timesheet information for Associates.
- Other Parties With Your Consent. Personal Information may also be disclosed to a third party such as a bank, mortgage company, lender, credit agency, landlord, prospective employer, relocation company, or travel agency, but only at your request and with your consent.
6. Retention of Personal Information
We store your Personal Information for as long as needed, or permitted, based on the reason we obtained it (consistent with applicable law). When deciding how long to keep your Personal Information, we consider whether we are subject to any legal obligations (e.g., any laws that require us to keep records for a certain period of time before we can delete them) or whether we have taken any legal positions that require data retention (e.g., issued any legal holds or otherwise need to preserve data). From time to time, we may also deidentify your Personal Information, retain it and use it in compliance with CCPA.
7. How You Can Update Your Personal Information
It is important that the information contained in our records is both accurate and current. We offer various self-help functions within our employment tools that will allow you to update your Personal Information. If your Personal Information changes during the course of your employment, you can use these self-help tools to update your Personal Information or you may contact Human Resources.
8. Your California Privacy Rights
A. Associate and Colleague Privacy Rights
The CCPA provides California residents with specific rights regarding Personal Information. This section describes your rights under the CCPA and explains how to exercise those rights. Subject to certain conditions and exceptions, Associates and Colleagues have the right to make the following requests:
- Right to Know/Access. With respect to the Personal Information we have collected about you, you have the right to request:
- The categories or Personal Information we collected about you;
- The categories of sources from which the Personal Information is collected;
- Our business or commercial purposes for collecting, selling, or sharing Personal Information;
- The categories of third parties to whom we disclosed Personal Information; and
- A copy of the specific pieces of Personal Information we have collected about you.
- Right to Correct. You have the right to request that we correct inaccuracies in your Personal Information. Associates and Colleagues seeking to update their information (for example to update your bank information for payroll or provide a new mailing address) may do so at any time by using the processes described in Section 7 above.
- Right to Delete. You have the right to request we delete your Personal Information. Please note, EmployBridge is not obligated to delete Personal Information that is necessary to provide services you request or to comply with applicable laws
- Right to Limit Use and Disclosure. We do not use or disclose “sensitive personal information” for purposes except as described in this Workforce Notice or as otherwise authorized by the CCPA.
- Right to Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.
We do not sell or share the Personal Information we collect from Employees, and we do not have actual knowledge that we sell or share the Personal Information of individuals under 16 years of age.
B. Exercising Your California Privacy Rights
To exercise any of these CCPA rights, please use one of the following methods:
- Email: privacy@employbridge.com
- Phone: (800) 605-8304
EmployBridge may require additional information to confirm your identity before fulfilling the request, such as your full name, the email address you used to communicate with us, and your address. In some cases, we may request additional information to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.
You may designate someone as an authorized agent to submit requests and act on your behalf. To do so, you must provide us with written permission to allow the authorized agent to act on your behalf. We may also ask you directly to verify that you have authorized your authorized agent to act on your behalf.
Note, this Privacy Policy applies only to rights and practices pursuant to the CCPA. These rights are in addition to any rights that may be available to you under the California Labor Code. To the extent you wish to exercise any rights pursuant to the Labor Code, please submit a Help Desk ticket to the People Success Center or contact them at PeopleSuccess@employbridge.com.
9. Contact Us
If you have questions or concerns regarding this Workforce Notice or the handling of your Personal Information, please contact us at:
EmployBridge Holding Company
1845 Satellite Blvd., Suite 300
Duluth, GA 30097
(800) 605-8304
PRIVILEGED AND CONFIDENTIAL – ATTORNEY-CLIENT PRIVILEGE – ATTORNEY WORK PRODUCT