California Consumer Privacy Act Notice
Upsourcemedia (the “Company”) is providing you with this Notice At Collection For Employees Residing in California Only (“Notice”) to inform you about:
- the categories of Personal Information that the Company collects about employees who reside in California; and
- the purposes for which the Company uses that Personal Information.
For purposes of this Notice,
“Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a natural person that the Company collects about its employees, who reside in California, in their capacity as the Company’s employees.
Identifiers And Professional Or Employment-Related InformationWe Collect
1.1 Personal Information Collected:
The Company collects identifiers and professional or employment-related information, including the following:
Identifiers: real name, nickname or alias, postal address, telephone number, e-mail address, Social Security number, signature, online identifier, Internet Protocol address, bank account name and number for direct deposits, driver’s license number or state identification card number, and passport number.
Professional or Employment-Related Information: compensation, bonuses, equity grants, pensions, benefits, attendance, evaluations, performance reviews, employee surveys, discipline, personnel files, expenses, membership in professional organizations, professional certifications, language skills, work eligibility in order to comply with legal requirements, and current and past employment history.
1.2 Purposes of Use:
|Monitoring, Security, And Compliance:|
|Conducting Our Business:|
Personal Information Categories From Cal. Civ. Code § 1798.80(e)
The Company collects categories of Personal Information listed in Cal. Civ. Code §1798.80(e) (other than those already listed in “Identifiers,” above) as follows for the purposes listed below:
- Photograph and physical description: with employee consent, (a) for security and internal identification purposes, and (b) to identify employees to co-workers, prospective and current customers, and other third parties.
- Medical information: (a) to the extent necessary to comply with the Company’s legal obligations, such as to accommodate disabilities; (b) to conduct a direct threat analysis in accordance with the Americans with Disabilities Act and state law; (c) for workers’ compensation purposes; (d) for occupational health surveillance; (e) for occupational health and safety compliance and record-keeping; (f) to conduct fitness-for-duty examinations; (g) to administer leaves of absence and sick time; (h) to respond to an employee’s medical emergency; and (i) to accommodate client screening requests.
- Benefits information: to assist in administering disability benefits.
Characteristics Of Protected Classifications Under California Or Federal Law
The Company collects information about race, age, national origin, disability, sex, and veteran status as necessary to comply with legal obligations, including the reporting requirements of the federal Equal Employment Opportunity Act, the federal Office of Contracting Compliance Programs (applicable to government contractors), and California’s Fair Employment and Housing Act. The Company also collects information about disability status to the extent an employee may need special assistance during emergencies from the Company or from first responders.
The Company also collects the following characteristics (in addition to those listed above) for its diversity and inclusion programs (including analytics): (a) religion, (b) sex, (c) gender, (d) pregnancy, (e) childbirth, (f) breastfeeding, or related medical conditions, (g) sexual orientation, (h) disability, (i) gender identity, (j) gender expression, (k) marital status, (l) age, (m) familial status, or (n) ancestry.
The Company also uses this Personal Information for purposes including: with respect to disability, medical condition, familial status, marital status, and pregnancy, childbirth, breastfeeding, and related medical conditions, as necessary to comply with Federal and California law related to leaves of absence and accommodation; with respect to military and veteran status, as necessary to comply with leave requirements under applicable law and for tax purposes; with respect to age, incidentally to the use of birth date for birthday celebrations and identity verification; with respect to religion and pregnancy, childbirth, breastfeeding, and related medical conditions, as necessary for accommodations under applicable law; with respect to protected classifications, such as national origin, to the extent this information is contained in documents that you provide in I-9 documentation; and with respect to marital status and familial status, for Company events and as necessary to provide benefits and for tax purposes.
The Company collects this category of Personal Information on a purely voluntary basis, except where required by law, and uses the information only in compliance with applicable laws and regulations.
- Biometric Information
- Personal Information Collected: The Company collects biometric information, including fingerprints and faceprints.
- Purposes of Use: to track clock-in and clock-out time using biometric information, to control access to secure facilities, to monitor use of Company and client information systems and other electronic resources or information systems, and to protect the safety and security of the Company’s and clients’ facilities.
- Internet Or Other Similar Network Activity
- Personal Information Collected: The Company collects information about employees’ use of the Internet or other similar network activity, including the following: browsing history, search history, log in/out and activity on the Company’s electronic resources, and information regarding an employee’s interaction with an Internet web site, application, or advertisement, and publicly available social media activity.
- Purposes of Use: to monitor use of the Company’s information systems and other electronic resources or information systems, to conduct internal audits, to conduct internal investigations, to protect the safety and security of the Company’s and clients’ facilities, and to impose discipline.
- Geolocation Data
- Personal Information Collected: The Company collects geolocation data, including the following: (a) information that can be used to determine a mobile device’s physical location; (b) information that can be used to determine a vehicle’s physical location; and (c) information that can be used to determine an employee’s physical location, for example, through a radio frequency identification (RFID) chip in a security badge.
- Purposes of Use: to assist with routing, to confirm that an employee has arrived and left an off-site work location when scheduled, for customer service purposes, to provide training, to manage employee-related emergencies, to monitor the safety of an employee, to monitor compliance with Company policies, and to determine whether to discipline employees.
- Sensory Or Surveillance Data
- Personal Information Collected: The Company collects sensory or surveillance data, including the following: recordings of customer service telephone calls and footage from video surveillance cameras.
- Purposes of Use: to protect the safety and security of the Company’s and clients’ facilities and personnel through video surveillance, to monitor compliance with Company policies, to provide training, for quality assurance, and to determine whether to discipline employees.
- Education Information
- Personal Information Collected: The Company collects education information, including the following: academic transcripts, educational discipline records, and academic counseling records.
- Purposes of Use: to determine suitability for placement at client sites, internal roles and promotions, to determine eligibility for training courses, and to assist with professional licensing.
- Profile Data
- Personal Information Collected: The Company collects profile data, including the following: psychological assessments, behavior analyses, or other profiling of its employees.
- Purposes of Use: to determine aptitude for certain positions and job assignments.
- Background Screening Information
- Personal Information Collected: The Company collects background screening information, including results of the following types of background screening: criminal history; sex offender registration; motor vehicle records; credit history; employment history; drug testing; and educational history.
- Purposes of Use: to screen employees for risks to the Company and its clients, and continued suitability for their jobs and to evaluate employees for promotions.
Purposes Potentially Applicable To Any Of The Categories Of Personal Information Listed Above
The Company also may use employees’ Personal Information to facilitate administrative functions and information technology operations and for legal reasons and corporate transactions. These functions include, but are not limited to the following:
- to manage and operate information technology and communications systems, risk management and insurance functions, budgeting, financial management and reporting, strategic planning;
- to manage litigation involving the Company, and other legal disputes and inquiries and to meet legal and regulatory requirements;
- in connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of the Company or any of its subsidiaries or affiliates; and
- to manage licenses, permits and authorizations applicable to the Company’s business operations.
Rights Under The California Consumer Privacy Act
Employees have the following rights regarding their personal information:
- the right to know what information has been collected by the Company about the employee (categories or specific information);
- the right to know where the information was obtained;
- the business purpose for which information was collected and/or obtained; and
- third party categories information is shared with, including government entities and law enforcement, affiliates and subsidiaries, and Company’s clients.
Access requests can be made twice every 12 months.
Employees have the right to request their personal information be corrected or deleted by the Company. Certain exceptions may apply. The Company may refuse correction or deletion requests if maintaining the information is required by law, or the law otherwise permits the Company to maintain the information. In the event a request is denied, the Company will provide a reason for the denial.
Data modification or deletion requests may be made to any location of the Company in person, via phone at + 319 -242 – 3555, via email to email@example.com, or via the online tool at https://upsourcemedia.com/request-a-proposal/Requests will be responded to within 45 days of receipt. In the event the Company cannot comply with the request within 45 days, a notice of extension will be provided during the initial 45-day period of the need for an extended time frame, up to an additional 45 days beyond the initial period.