This California Applicant/Employee/Contractor Privacy Notice applies to job applicants, employees, owners, directors, officers, medical staff members, or contractors of Altus Group residing in California from whom we collect Personal Information as a business under California law.

Personal Information Collection

For the purposes of this notice, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).

Personal Information does not include information that is:

  • Lawfully made available from government records.
  • Deidentified or aggregated.
  • Otherwise excluded from the scope of the CCPA.

The chart below provides the categories of Personal Information (as defined by the CCPA) we collect from job applicants, employees, owners, directors, officers, medical staff members, or contractors. The examples of Personal Information provided for each category reflect each category’s statutory definition and may not reflect all of the specific types of Personal Information associated with each category.

Category

We Collect

A. Identifiers

Examples: Name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

Yes

B. Categories of Personal Information in Cal. Civ. Code Section 1798.80(e)

 

Examples: Name, signature, social security number, physical characteristics or description, address, telephone number, passport 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.

Yes

C. Characteristics of Protected Classifications under California or Federal Law

 

Examples: Race or color, ancestry or national origin, religion or creed, age (over 40), mental or physical disability, sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions), sexual orientation, gender identity or expression, medical condition, genetic information, marital status, military and veteran status.

Yes

D. Commercial Information

 

Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Yes

E. Biometric Information

 

Examples: Physiological, biological, or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

No

F. Internet or Other Electronic Network Activity Information

 

Examples: Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement.

Yes

G. Geolocation Data

 

Example: Precise physical location.

No

H. Sensory Information

 

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Yes

I. Professional or employment-related information

 

Examples: Job application or resume information, past and current job history, and job performance information.

Yes

J. Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99)

 

Examples: Records that are directly related to a student maintained by an educational agency or institution or by a party acting for the agency or institution.  

No

K. Inferences Drawn from Personal Information

 

Examples: Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Yes

Use of Personal Information

We collect and use your Personal Information in accordance with the specific business purposes below:

  1. Recruitment: To receive, evaluate, and process job applications, verify your information and conduct background checks, as permitted by law, communicate with you about the recruitment process and your application, schedule interviews, and improve the recruitment process.
  2. HR Operations: To fulfill your employment agreement, manage employee onboarding, promotions, transfers, and secondments, manage HR related claims and litigation, provide trainings, performance reviews, and evaluations, manage business and travel expenses, and create reports for workforce planning, such as headcount and employee turnover.
  3. Payroll and Benefits: To administer pay and benefits, process business and travel expense reimbursements, calculate tax and social security withholdings, comply with wage garnishment orders, and process leaves.
  4. IT and Security: To provide IT and security support, manage IT resources and provisions of new IT applications, manage log-in credentials, monitor IT systems and networks for suspicious activity, detect intrusions, and monitor and control access to facilities to protect us, our personnel, and property.
  5. Legal and Compliance: To comply with legal obligations regarding HR analytics, including requests from government statistics services, process conflict of interest reporting, process employee work-related claims such as worker compensation or insurance claims ensure compliance with our employee policies and security requirements gather evidence for and to support any internal investigations, litigation, disciplinary action, termination, or related activities, protect, enforce, and defend the legal rights, privacy, safety, or property of us and our employees, agents, and contractors, protect against fraud and manage risk, and comply with applicable laws, regulations, legal processes, or enforceable governmental requests.
  6. Acquisition or Merger: To manage acquisitions, mergers, and reorganizations or sale of some or all of a company.

Other Business Purposes: For other purposes that you would reasonably expect, or for which we provide specific notice at the time the information is collected.

Updates to this Notice

We may revise this notice from time to time. For the latest version of this notice, you may email privacyoffice@altusgroup.com and request a copy.

Contact information

If you have any questions, comments, or concerns about our processing activities, please contact your HR representative.

Last Updated: July 1, 2020

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