This California Notice at Collection (the “Notice”) provides information required under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”). This Notice explains how CBTS Technology Solutions LLC (“CBTS”) and OnX Enterprise Solutions Ltd. (“OnX”) (collectively, “Company” “we,” “us,” “our”) collects, uses, discloses, and/or retains personal information (“Personal Information”) about Company employees (“Employees”), independent contractors (“Contractors”), and job applicants (“Job Applicants”) (collectively “you” or “your”) when engaged in an employment related context.
- Definitions
- Personally Identifiable Information (“PII” or “Personal Information”): PII is any information: (i) that directly identifies an individual (e.g., real name, address, other identifying number, unique personal identifier, email address, account name, social security, driver’s license number, passport, etc.) or (ii) by which an agency intends to identify specific individuals in conjunction with other data elements, i.e., indirect identification, such as signature, telephone number, education, employment, etc.
- Sensitive PII (“SPII” or “Sensitive Personal Information”): Sensitive PII is PII that reveals more sensitive information regarding an individual, such as: social security number, driver’s license number, state identification card number, passport number, racial or ethnic origin, union membership, or the contents of an individual’s mail, email, and text messages. SPII also includes information concerning the Applicant or Employee’s health, sex life, sexual orientation.
- “Service Providers” and “Third Party”: Have the meanings afforded to it in the CCPA.
- To the extent other terms used in this Notice are defined terms under the CCPA, they shall have the meanings afforded to them in those statutes, whether or not these terms are capitalized herein.
- Collection & Processing of Personal Information
The section identifies the categories of Personal Information which may be collected from you and the purposes for which the Personal Information will be used, including whether that information will be sold or shared.
- Identifiers, such as name, email address, accounts number, Social Security number (“SSN”), driver’s license number, passport number or similar identifier;
- Financial information, medical information, health insurance information;
- Characteristics of protected classifications under state or federal law, such as age, religion, gender, race, physical or mental health conditions, and marital status;
- Commercial information, such as transaction information and purchase history;
- Internet or other electronic network activity information, such as browsing history and interactions with our websites or advertisements;
- Geolocation data, such as device location;
- Audio, electronic, visual and similar information, such as call and video recordings;
- Professional or employment-related information, such as work history and prior employer;
- Education information, as defined in the federal Family Educational Rights and Privacy Act, such as student records; and
- Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences, characteristics, trends, abilities, and aptitudes.
- Sensitive Personal Information, including:
- Personal Information that reveals:
- Social security, driver’s license, state identification card, or passport number;
- Financial account number;
- Racial or ethnic origin;
- Contents of a Employees, Contractors, and Job Applicants email and text messages, unless the business is the intended recipient thereof; or
- Personal Information Collected and analyzed concerning a Employees, Contractors, and Job Applicants health; and
- Personal Information Collected and analyzed concerning a Employees, Contractors, and Job Applicants sex life or sexual orientation.
- Categories of Personal Information Disclosed to Service Providers/Third Parties
We may disclose the following categories of Personal Information to our Service Providers/Third Parties:
- Identifiers, such as name, email address, accounts number, Social Security number (“SSN”), driver’s license number, passport number or similar identifier;
- Financial information, medical information, health insurance information;
- Characteristics of protected classifications under state or federal law, such as age, religion, gender, race, physical or mental health conditions, and marital status;
- Internet or other electronic network activity information, such as browsing history and interactions with our websites or advertisements;
- Geolocation data, such as device location;
- Audio, electronic, visual and similar information, such as call and video recordings;
- Professional or employment-related information, such as work history and prior employer;
- Education information, as defined in the federal Family Educational Rights and Privacy Act, such as student records; and
- Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences, characteristics, trends, abilities, and aptitudes.
- Sensitive Personal Information, including:
- Personal Information that reveals:
- Social security, driver’s license, state identification card, or passport number;
- Financial account number;
- Racial or ethnic origin;
- Contents of Employees, Contractors, and Job Applicants email and text messages, unless the business is the intended recipient thereof; or
- Personal Information Collected and analyzed concerning Employees, Contractors, and Job Applicants health; and
- Personal Information Collected and analyzed concerning Employees, Contractors, and Job Applicants sex life or sexual orientation.
- Sources From Which We Collect Applicant, Employee, and Contractor Personal Information
We collect Personal Information from:
- Applicants, Employees, and Contractors when they complete recruiting and employment forms;
- Service Providers and Third Parties that help us screen individuals for hiring purposes, and when they share the information with us; and
- Joint marketing partners, public databases, professional organizations, educational institutions, and social media platforms.
- Purposes for Processing Personal Information
We and our Third Parties collect Personal Information to use or disclose as appropriate to:
- Comply with all applicable laws and regulations;
- Recruit and evaluate job applicants and candidates for employment;
- Conduct background checks;
- Manage your employment relationship with us, including for:
- onboarding processes;
- timekeeping, payroll, and expense report administration;
- employee healthcare and benefits administration;
- employee training and development requirements;
- the creation, maintenance, and security of your online employee accounts;
- reaching your emergency contacts when needed, such as when you are not reachable or are injured or ill;
- workers’ compensation claims management;
- employee job performance, including goals and performance reviews, promotions, discipline, and termination; and
- other human resources purposes.
- Manage and monitor employee access to company facilities, equipment, and systems.
- Conduct internal audits and workplace investigations;
- Investigate and enforce compliance with and potential breaches of Company policies and procedures;
- Engage in corporate transactions requiring review of employee records, such as for evaluating potential mergers and acquisitions of the Company;
- Maintain commercial insurance policies and coverages, including for workers’ compensation and other liability insurance;
- Perform workforce analytics, data analytics, and benchmarking;
- Administer and maintain the Company’s operations, including for safety purposes.
- For client marketing purposes;
- Exercise or defend the legal rights of the Company and its employees, customers, contractors, and agents;
- Operate, manage, and maintain our business;
- Perform accounting, audit, and other internal functions, such as internal investigations.
- Exercise and defend legal claims; and
- Otherwise accomplish our business purposes and objectives.
In addition to the purposes identified above, CBTS may use and disclose Employee Personal Information that we Collect as necessary or appropriate to:
- Comply with laws and regulations, including (without limitation) applicable tax, health and safety, anti-discrimination, immigration, labor and employment, and social welfare laws;
- Monitor, investigate, and enforce compliance with and potential breaches of CBTS policies and procedures and legal and regulatory requirements;
- Comply with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons; and
- Exercise or defend the legal rights of CBTS and its employees, affiliates, customers, contractors, and agents.
Service Providers. We may disclose your Personal Information to our Service Providers for the purposes described in Section E of this Notice, to provide:
- Applicant selection and related hiring services,
- Benefits and wellness services,
- Website services, and
- Other products and services, such as web hosting, data analysis, customer service, infrastructure services, technology services, email delivery services, legal services, and other similar services.
We grant our Service Providers access to Employee Personal Information only to the extent needed for them to perform their functions and require them to protect the confidentiality and security of such information.
Third Parties. We may disclose your Personal Information to our Third Parties for the purposes described in Section E of this Notice:
- At Your Direction. We may disclose your Personal Information to any Third Party with your consent or at your direction.
- Business Purpose. We may disclose your Personal Information to a Third Party for a business purpose.
- Legal and Regulatory. We may disclose your Personal Information to government authorities, including regulatory agencies and courts, as reasonably necessary for our business operational purposes, to assert and defend legal claims, and otherwise as permitted or required by law.
- Selling to Third Parties or Sharing with Third Parties for Cross-Context Behavioral Advertising
We do not Sell or Share Personal Information. Further, we do not use Sensitive Personal Information for purposes beyond those authorized by the CCPA. Relatedly, we do not Sell or Share Personal Information of California Employees, Contractors, and Job Applicants under 16 years of age with third parties for cross context behavioral advertising.
For purposes of the CCPA, a “Sale” is the disclosure of Personal Information to a Third Party for monetary or other valuable consideration, and a “Share” is the disclosure of Personal Information to a Third Party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.
- Your Data Rights as a California Resident Applicant, Employee, or Contractor
As an Applicant, Employee, or Contractor, you have the following rights regarding our Collection and use of your Personal Information, subject to certain exceptions. To obtain any of the information provided herein, please refer to the “Submitting a Verified Customer Request” section below for instructions on how to submit a request to receive, delete, correct, or opt-out regarding your Personal Information.
As an Applicant, Employee, or Contractor, you have the following rights regarding our Collection and use of your Personal Information:
- Right to Receive Information on Privacy Practices. We have provided such information in this Policy, and you may request further information about our privacy practices by contacting us at the contact information provided below.
- Right to Deletion: You may request that we delete any Personal Information about you that we that we collected from you.
- Right to Correction: You may request that we correct any inaccurate Personal Information we maintain about you.
- Right to Know: You have the right to request any of the following:
- The categories of Personal Information we have collected from you
- The categories of sources from which the Personal Information is collected
- The business purpose for collecting, selling, or sharing with third parties for cross context behavioral advertising (e.g. targeted advertising), though CBTS does not permit this
- The categories of third parties to whom we disclose personal information
- The specific piece of personal information we have collected about you.
- Right to Receive Information About Onward Disclosures: You may request that we disclose to you the categories of Personal Information that we have disclosed, Sold or Shared about you, the categories of persons to whom we disclosed your Personal Information, and the categories of Third Parties to whom the Personal Information was Sold or Shared.
- Right to Opt-Out of the Sale and Sharing of Your Personal Information and to Limit the Use of Your Sensitive Personal Information: You have the right to opt-out of the Sale and Sharing of your Personal Information. You also have the right to limit the use of your Sensitive Personal Information to the purposes authorized by the CCPA.
- Right to Non-Discrimination: You have the right not to be discriminated against for exercising your data subject rights. We will not discriminate against you for exercising your data subject rights.
- Other
- Retention of Personal Information: We retain each of the above-listed categories of Personal Information for the duration of your Applicant and/or Employee relationship with us, as applicable, and longer as may be required by applicable laws or necessary for our legitimate business purposes.
- Changes to our Notice. We reserve the right to amend this Notice at our discretion and at any time. Please review it occasionally to keep up to date on our privacy practices. If changes are made to this Notice, it will be updated in a timely manner and the date at the top of the Notice will reflect the date it was last updated.
- Submitting a Verified Consumer Request. You have the right to submit verified consumer requests to know information, correct information, or for deletion. You may submit a request to know information, to correct information, or for deletion via email at Privacy@cbts.com or by calling us at (866) 712-8077.
We may need you to provide additional information to verify your request, such as providing certain data elements so that we can confirm they match the Personal Information already maintained by us. We will not use this additional information for anything other than handling your request.
If you submit a request that is not through one of these designated methods or is deficient in some manner unrelated to verification, we will provide you with information on how to submit the request or remedy any deficiencies.
Once we receive your verifiable request, we will confirm receipt of the request within ten (10) business days describing our verification process. We will respond to your request to opt-out of the sale or sharing as soon a feasibly possible up to a maximum of fifteen (15) business days from the initial date a request is received, if we are able to verify your identity. We will respond to your request to know, delete, or correct your data within forty-five (45) calendar days from the initial date a request is received, if we are able to verify your identity.
- Contacting Us. If you have any questions, comments, requests, or concerns related to this Notice, CBTS’s information practices, or how to access this Policy in another format, please contact us at CBTS Technology Solutions LLC, 25 Merchant Street, Cincinnati, OH 45246, and/or at Privacy@cbts.com for assistance. You may also authorize an agent to make a data subject request on your behalf, and the authorized agent may do so via the above-listed submission methods.
