Privacy Notice for California Job Applicants, Employees, Contractors and Their Emergency Contacts

Last Updated: March 11, 2020

This Privacy Notice for California Job Applicants, Employees, Contractors and Their Emergency Contacts (“Privacy Notice”) applies to personal information of California residents only to the extent the information is subject to the California Consumer Privacy Act of 2018 (CCPA). This Privacy Notice applies to job applicants, employees, contractors, and their emergency contacts who are California residents. It does not apply to personal information covered by HIPAA or to personal information otherwise excepted from the CCPA. Any terms defined in the CCPA have the same meaning when used in this Privacy Notice.

This Privacy Notice pertains to personal information we have collected in the last twelve (12) months.

Personal Information We Collect

We collect 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 (“personal information”). We may collect the following categories of your personal information:

Category of Personal Information	Examples
Identifiers (“Identifiers”)	Name, alias, postal address, social security number, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.
Personal Information Categories Listed in the California Customer Records statue (Cal. Civ. Code 1798.80(e)) (“Other PI”)	Name, signature, social security number, address, telephone number, passport number, driver’s license or state identification card number, annuity contract number, insurance policy number, employment, employment history, bank account number, or any other financial information or health information. Some personal information included in this category may overlap with other categories.
Characteristics of protected classifications under California or federal law (“Characteristics”)	Age (40 year and 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.
Commercial Information (“Commercial”)	Records of personal property, products or services purchased, obtained or considered.
Biometric Information (“Biometric”)	Physiological, biological or behavioral characteristics, including fingerprint and voice recordings, from which an identifier template, such as a voiceprint can be extracted, and keystroke patterns or other physical patterns.
Internet or other electronic network activity information (“Internet Activity”)	Browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
Geolocation data (“Geolocation”)	Physical location and/or movements.
Sensory data (“Sensory”)	Audio, electronic, visual, or similar information.
Professional or employment-related information (“Professional”)	Current and/or past employment history, professional licenses or affiliations. Education records for maintaining continuing education requirements.
Non-public education information (as defined in the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)) (“Education”)	Education records, files, documents, and other materials directly related to a student maintained by an educational agency or institution or by a person acting for such an agency or institution, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records
Inferences drawn from other personal information (“Inferences”)	Information used to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Uses and Disclosures of Personal Information

We may use the categories of personal information for the following purposes:

Category of Personal Information	Purposes
All Categories	To fulfill or meet the purpose for which you provided the information To contact you with regard to your relationship with us, respond to your inquiries, and otherwise communicate with you To contact third parties whose contact information you provide to us in case of an emergency or otherwise as permitted by applicable law To allow you access to our technology assets, accounts, and physical premises To help maintain the safety, security, and integrity of our technology assets, information or accounts you may have with us, and our physical premises To administer our policies and procedures and to investigate any potential violations of our policies or procedures or contract of employment To report information to government agencies as required by applicable law, and otherwise to comply with applicable laws and government programs in which we participate To respond to law enforcement requests and as required by applicable law, court order, or local, state, or federal government regulations As necessary or appropriate to protect the rights, property, or safety of us, our clients or others, including in connection with obtaining legal advice or establishing or defending our rights For other company-related programs or services, including but not limited to administering our drug-free workplace program, coordinating business-related travel, allowing use of company-owned automobiles To provide, support, and improve our website and services relating to your employment or potential employment For internal business purposes
Identifiers Other PI Characteristics Commercial Biometric Geolocation Sensory Professional Education Inferences	To administer payroll, payment of expenses, and other employee benefits, such as leave of absence, employee wellness programs, retirement plans, medical insurance, education reimbursement, or bonuses
Identifiers Other PI Characteristics Commercial Biometric Geolocation Sensory Professional Education Inferences	To confirm your eligibility for employment or other professional engagement, such as conducting a background check, obtaining a consumer report or investigative consumer report about you, verifying your identity, and confirming your authorization to work in the US
Identifiers Other PI Characteristics (if provided) Internet Activity Sensory Professional Education Inferences	For recruitment, processing your job application, and assessing your candidacy for employment or other professional engagement with us
Identifiers Other PI Internet Activity Geolocation Sensory Professional Education Inferences	To evaluate your performance as an employee or other professional engagement with us
Identifiers Other PI Commercial Internet Activity Sensory Professional Inferences	To provide you with information about products or services from business partners that we think may be of interest to you

Changes to this Privacy Notice

This Privacy Notice may be changed from time to time. The date noted on the Privacy Notice indicates when it was last revised.

Contact Information

If you have questions about this notice, please contact us at:
Phone: 1-866-723-3149
Email: ccpa@gaig.com

This Privacy Notice is not a contract for employment and does not alter the employment ‎at-will relationship between us and any employee. ‎