Introduction
This Privacy Notice for California ManageAmerica Personnel (the “California PersonnelPrivacy Notice”) applies solely to all job applicants to, and current or former employees of, owners of, directors of, officers of, and contractors of ManageAmerica Integrated Billing ServicesLLC (“ManageAmerica,” “we,” “us,” or “our”) who reside in the State of California(“Personnel” or “you”). We adopt this California Personnel Privacy Notice to comply with theCalifornia Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of2020 (collectively, the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this California Personnel Privacy Notice.
Scope of this California Personnel Privacy Notice
This California Personnel Privacy Notice applies to information that we collect aboutManageAmerica Personnel that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your device(“Personal Information”). “Personal Information” includes all “Sensitive Personal Information”as defined below. However, publicly available information that we collect from government records and deidentified or aggregated information (when deidentified or aggregated as required under the CCPA) are not considered Personal Information and this California Personnel PrivacyNotice does not apply.
This California Personnel Privacy Notice does not apply to outside of the context of your relationship with ManageAmerica as ManageAmerica Personnel or to certain PersonalInformation that is excluded from the scope of the CCPA, like: (a) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and theCalifornia Confidentiality of Medical Information Act (CMIA); (b) Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA); and (c)other laws or information that is excluded from the scope of the CCPA. Some of these exclusions may be applicable to the Personal Information we collect about you as part of background checks.If you have any questions on whether one of these exceptions apply to your Personal Information, please contact the Human Resources department.
Information We Collect About You and How We Collect It
ManageAmerica collects, and over the prior twelve (12) months has collected, the following categories of Personal Information about ManageAmerica Personnel:
Identifiers.
Applicable Pieces of Personal Information Collected: A real name; alias; postal address; unique personal identifier; online identifier; Internet Protocol address (when you access our network resources); email address; username; Social Security number; and other similar identifiers. If provided by you as proof of eligibility to work or as part of your business travel profile, driver’s license number and/or passport number.
Personal information categories listed in the California Customer Records statute (Cal. Civ.Code § 1798.80(e)).
A 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 or debit card number; medical information; and health insurance information. If provided by you as proof of eligibility to work or as part of your business travel profile, passport number, driver’s license, and/or state identification card number. Note: Some Personal Information included in this category may overlap with other categories.
Protected classification characteristics under California or federal law.
Required: Age (40 years or older); national origin; or citizenship. Note: We require your age to verify your identity, run background checks, and to provide you with health and retirement benefits. We require your national origin and citizenship to verify your eligibility to work in the United States. You are not required to provide us with this information for any other uses. Optional: Race; color; ancestry; religion or creed; marital status; medical condition; physical or mental disability; sex (including gender; gender identity; gender expression; pregnancy or child birth and related medical conditions); sexual orientation; and veteran or military status. Note: Providing this information is completely optional at your discretion, and we will collect this information only to the extent you choose to provide it in your resume, as part of the equal opportunity forms you fill out when you are hired, or as may be provided by a reference or other third party during reference and background checks.
Internet or other similar network activity.
Browsing history; search history; file access history; information on your interaction that occurs on our networks (including via VPN) with a website or application.
Sensory data.
Audio; electronic; visual; or similar information.
Professional or employment-related information.
Current or past job history or performance evaluations.
Inferences drawn from other Personal Information.
Profile reflecting a person’s preferences; characteristics; psychological trends; predispositions; behavior; attitudes; intelligence; abilities, and aptitudes.
Sensitive Personal Information
- Government identifiers (social security; driver’s license; state identification card; or passport number). This may be provided by you as proof of eligibility to work or as part of your travel profile.
- Complete account access credentials (user names; account numbers; or card numbers combined with required access/security code or password);• Racial or ethnic origin (see note below);
- Religious or philosophical beliefs (see note below);
- Mail, email, or text messages contents not directed to us;
- Health (see note below);
- Sex life; or sexual orientation information (see note below).
Note: Providing information about your racial or ethnic origin, religious or philosophical beliefs, and health, sex life, or sexual orientation is completely optional at your discretion, and we will collect this information only to the extent you choose to provide it in our resume, as part of the equal opportunity forms you fill out when you are hired, or as may be provided by a reference or other third party during reference and background checks.
ManageAmerica will not collect additional categories of Personal Information without providing you notice. We do not “sell” any categories of Personal Information for monetary or other valuable consideration and we do not “share” any categories of Personal Information for cross-context behavioral advertising.
Sources of Personal Information
We collect this Personal Information:
- Directly from you when you provide it to us;
- From third parties, such as prior employers, references, recruiters, and job-related socialmedia platforms, background check companies, drug testing facilities (if you are required to submit to a drug test as a condition of your employment or continued employment), and other similar entities;
- When you use our information technology systems or access our facilities; and
- We also create this information during the course of your employment relationship withManageAmerica.
Information You Provide to Us
We collect information directly from you before, after, and during relationship withManageAmerica as part of ManageAmerica Personnel. Depending on nature of your role or relationship with ManageAmerica as ManageAmerica Personnel, we may collect PersonalInformation from you such as your name, address, social security number (or national ID number), a list of your beneficiaries, work history, educational history, personal and work preferences (and any other information you may voluntarily disclose on your application or resume), date of birth, marital status, picture, dependents (and their dates of births, social security numbers or other national ID numbers), immigration status, gender, ethnicity, veteran status, disabilities, personal 4email, banking information (in order to pay you your salary or other compensation and to reimburse you for expenses in accordance with ManageAmerica’s expense reimbursement policies), number of tax exemptions (where applicable), emergency contact information, and personal phone number. We may also collect your passport number, driver’s license number or image, and vehicle registration or license plate number when required or when you provide it for your travel profile. We may also collect your nationality, tax ID number, criminal history, and information for background checks.
Some of the Personal Information we collect from you is required to enter into an agreement withManageAmerica related to your position as ManageAmerica Personnel, and for ManageAmerica to perform under such an agreement. If you refuse to provide such Personal Information, then in some cases we may not be able to enter into such an agreement for you to be ManageAmericaPersonnel or fulfill our obligations to you under it.
Information We Create About You
In addition to the Personal Information that you may provide to ManageAmerica, ManageAmerica also creates certain Personal Information about you and associates it with you. ManageAmerica creates the following types of Personal Information about you: job title, employee number, badge number, salary, expense, and other related compensation details, employment status, information regarding mandatory training, vacation/holiday pay and other paid time off, disciplinary and grievance information, tax records, performance history, office access records and video surveillance records (where applicable) system access information such as your ManageAmerica username to access our technology systems, email address, telephone number, and password (which you may change). We may also collect and process information specifically related to your job function, such as sales and production volumes. We may also photograph you to include in the employee directory and/or to issue you a badge to access and be identified at ManageAmerica’s facilities.
Information We Collect Through Automatic Data Collection Technologies
As you use ManageAmerica’s information technology systems, we may collect information about your use necessary to protect our information technology and infrastructure. We may collect time, date, and location information of access to our information technology systems and the data contained on those systems. We may also monitor, intercept, and review your activities when you use our information technology resources and communications systems, including but not limited to email (both outgoing and incoming), telephone conversations, and voice mail recordings, and instant messages. Our facilities may also deploy video and other similar recording technologies which may be operated by a third party owner or operator of the buildings where our facilities are located.
Information We Collect from Third Parties
ManageAmerica also collects Personal Information about you from third parties, such as prior employers, references, recruiters, and job-related social-media platforms, background check companies, drug testing facilities (if you are required to submit to a drug test as a condition of your employment or continued employment), and other similar entities. This may include PersonalInformation that is disclosed in background checks, which may include criminal convictions, drug testing, and any information that is disclosed from your former employers, educational institutions, 5and other references you list on your application materials or that are referred to us. We may also collect Personal Information provided from recruiters and job-related social media platforms that you may use to submit your application, such as information on your resume or other information related to your previous or desired employment, if your application to us is provided through a recruiter or a job-related social media platform. To the extent permitted by applicable law, we may also collect Personal Information from general social media platforms.
Purposes for Our Collection of Your Personal Information
Depending on your role or relationship with ManageAmerica, we may use the Personal Information we collect for one or more of the following purposes:
- recruiting, including identifying and evaluating job applicants, including assessing skills, qualifications, and interests for the purposes of determining suitability for the position forwhich you have applied;
- if you are an employee of ManageAmerica, delivering or administering your salary and benefits, including insurance and retirement benefits;
- if you are a contractor of ManageAmerica, providing you with your agreed upon compensation;
- managing our workforce and, if you are an employee of ManageAmerica, your career;
- delivering training programs, and measuring and recording the results of training;
- communicating with you and for you to communicate with other ManageAmericaPersonnel and other third parties;
- collecting and maintaining information about your work history and work performance;
- investigating accidents and claims of wrongdoing, including to collect evidence for possible grievance or disciplinary actions or legal disputes;
- to run and manage business operations, including to schedule work, manage the business organization, business assets, travel and expense reimbursement, managing corporate credit cards and card payment history, maintaining corporate contact directories and organizational charts, managing and storing records;
- processing IT infrastructure, including email, internet, social media systems, and file shares;
- maintaining the security and safety of our facilities, personnel, and other assets, including to authenticate personnel to access ManageAmerica’s IT resources and facilities, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
- to conduct screening and background and compliance checks before and during the time you are considered ManageAmerica Personnel and maintaining records on such screening and checks;
- if you are an employee, providing employee programs such as on-site health services, company cars, pension schemes, stock options, and other similar benefits;
- to comply with legal requirements, including to withhold taxes, and to report accidents, salary, and tax information to regulatory authorities;
- to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
- to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of ManageAmerica’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by ManageAmerica about ManageAmerica Personnel is among the assets transferred;
- in order to publish your name, picture, and contact information in our internal employee directory and, for leadership positions, to publish your online biography and for similar marketing efforts in accordance with ManageAmerica’s policies; and
- as described to you when collecting your Personal Information or as otherwise set forth inapplicable law.ManageAmerica will not use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Third Parties to Whom Do We Disclose Your Personal Information for BusinessPurposes
ManageAmerica may disclose your Personal Information to third parties for one or more business purposes related to your role as ManageAmerica Personnel. When we disclose PersonalInformation to unaffiliated third parties for business purposes, we enter a contract that includes:(a) a description of the business purposes; (b) requires the recipient to both keep that PersonalInformation confidential and not use it for any purpose except for the purposes for which thePersonal Information was disclosed; and (c) requires the recipient to otherwise comply with the requirements of the CCPA.
ManageAmerica discloses and, in the preceding twelve (12) months, ManageAmerica has disclosed the following categories of Personal Information of its ManageAmerica Personnel to the following categories of third parties for one or more of the business purposes described below:
Personal Information Category and Categories of Third Party Recipients
Identifiers.
Service providers (who manage our employee data, such as our enterprise resource planning systems and other systems that we use to manage our workforce); benefits providers; building or property management and security personnel; affiliates, parents, and subsidiary organizations of ManageAmerica; government entities(for taxes and other similar purposes that require us to providePersonal Information to government entities); business partners; credit reporting agencies (for background checks).
Personal information categories listed in the California Customer Records statute (Cal.Civ. Code §1798.80(e)).
Service providers (who manage our employee data, such as our enterprise resource planning systems and other systems that we use to manage our workforce); benefits providers; building or property management and security personnel; affiliates, parents, and subsidiary organizations of ManageAmerica; government entities(for taxes and other similar purposes that require us to providePersonal Information to government entities); business partners; credit reporting agencies (for background checks).
Protected classification characteristics underCalifornia or federal law
Service providers (who manage our employee data, such as our enterprise resource planning systems and other systems that we use to manage our workforce); benefits providers; building or property management and security personnel; affiliates, parents, and subsidiary organizations of ManageAmerica; government entities(for taxes and other similar purposes that require us to providePersonal Information to government entities); business partners; credit reporting agencies (for background checks).
Internet or other similar network activity.
Service providers (who manage our IT systems, such as security providers and IT providers); affiliates, parents, and subsidiary organizations of ManageAmerica.
Sensory data.
Service providers (who manage our employee data, such as our enterprise resource planning systems and other systems that we use to manage our workforce as well as our email providers); affiliates, parents, and subsidiary organizations of ManageAmerica. This may also be disclosed with the general public if you appear on our websites.
Professional or employment-related information.
Service providers (who manage our employee data, such as our enterprise resource planning systems and other systems that we use to manage our workforce); affiliates, parents, and subsidiary organizations of ManageAmerica.
Non-public education information (per theFamily EducationalRights and Privacy Act(20 U.S.C. Section1232g, 34 C.F.R. Part99)).
Service providers (who manage our employee data, such as our enterprise resource planning systems and other systems that we use to manage our workforce); affiliates, parents, and subsidiary organizations of ManageAmerica.
Inferences drawn from other PersonalInformation
Service providers (who manage our employee data, such as our enterprise resource planning systems and other systems that we use to manage our workforce); affiliates, parents, and subsidiary organizations of ManageAmerica.
Sensitive Personal Information Category and Categories of Third Party Recipients
Government identifiers (social security, driver’s license, state identification card, or passport number)
Service providers (who manage our employee data, such as our enterprise resource planning systems and other systems that we use to manage our workforce); benefits providers; building or property management and security personnel; affiliates, parents, and subsidiary organizations of ManageAmerica; government entities(for taxes and other similar purposes that require us to provide Personal Information to government entities); business partners; credit reporting agencies (for background checks).
Complete account access credentials (usernames, account numbers, or card numbers combined with required access/security code or password)
Service providers (who manage our employee data, such as our enterprise resource planning systems and other systems that we use to manage our workforce, including IT and other similar providers); and affiliates, parents, and subsidiary organizations of ManageAmerica
Racial or ethnic origin
Service providers (who manage our employee data, such as our enterprise resource planning systems and other systems that we use to manage our workforce); affiliates, parents, and subsidiary organizations of ManageAmerica; government entities (for employment reporting purposes).
Religious or philosophical beliefs
We do not disclose this type of Personal Information.
Mail, email, or text messages contents not directed to us
We generally do not know of the existence of any such mail, email, or text messages. However, there should be no expectation of privacy in any such messages received or transmitted usingManageAmerica IT systems. Such messages may be disclosed to service providers; affiliates, parents, and subsidiary organizations of ManageAmerica; and law enforcement personnel as appropriate.
Health, sex life, or sexual orientation information
Service providers (who manage our employee data, such as our enterprise resource planning systems and other systems that we use to manage our workforce); and affiliates, parents, and subsidiary organizations of ManageAmerica (if you choose to provide it to us).
We disclose your Personal Information to the categories of third parties listed above for the following business purposes:
- Helping to ensure security and integrity of our facilities and IT infrastructure to the extent the use of the Personal Information is reasonably necessary and proportionate for these purposes.
- Performing services on behalf of us, including maintaining or servicing accounts; providing Human Resources services; processing or fulfilling payroll and other similar transactions; verifying ManageAmerica Personnel information; providing analytic services; providing storage; or providing similar services on behalf of us.
- Providing retirement, health, and other benefits, services, or products to which Personnel and their dependents or beneficiaries receive through ManageAmerica.
In addition to the above, we may disclose any or all categories of Personal Information to any third party (including government entities and/or law enforcement entities) as necessary to:
- comply with federal, state, or local laws, or to comply with a court order or subpoena to provide information;• comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
- cooperate with law enforcement agencies concerning conduct or activities that we (or one of our service providers’) believe may violate federal, state, or local law;
- comply with certain government agency requests for emergency access to your PersonalInformation if you are at risk or danger of death or serious physical injury;
- to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of ManageAmerica’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by ManageAmerica about ManageAmerica Personnel is among the assets transferred; or
- exercise or defend legal claims.
To Whom Do We Sell or Share Your Personal Information
“Sale” of Your Personal Information
In the preceding twelve (12) months, ManageAmerica has not “sold” Personal Information foreither monetary or other valuable consideration, and we have not “sold” any Personal Informationabout minors under the age of 16.
“Sharing” of Your Personal Information for Cross-Context Behavioral Advertising
In the preceding twelve (12) months, ManageAmerica has not “shared” Personal Information forthe purpose of cross-context behavioral advertising, and we have not “shared” any PersonalInformation about minors under the age of 16.
Personnel Data Requests
The CCPA provides ManageAmerica Personnel with specific rights regarding their PersonalInformation. This section describes these rights and explains how to exercise those rights. You may exercise these rights yourself or through your Authorized Agent. For more information on how you or your Authorized Agent can exercise your rights, please see Exercising Your CCPA Privacy Rights.
- Right to Know. You have the right to request that ManageAmerica disclose certain information to you about our collection and use of your Personal Information over the past12 months (a “Right to Know” request). This includes: (a) the categories of PersonalInformation we have collected about you; (b) the categories of sources from which that 10Personal Information came from; (c) our purposes for collecting this Personal Information;(d) the categories of third parties with whom we have shared your Personal Information; and (e) if we have “sold” or “shared” or disclosed your Personal Information, a list of categories of third parties to whom we “sold” or “shared” your Personal Information, and a separate list of the categories of third parties to whom we disclosed your PersonalInformation to. You must specifically describe if you are making a Right to Know requestor a Data Portability Request. If you would like to make both a Right to Know PersonnelRequest and a Data Portability Personnel Request you must make both requests clear in your request. If it is not reasonably clear from your request, we will only process your request as a Right to Know request. You may make a Right to Know or a Data PortabilityPersonnel Request a total of two (2) times within a 12-month period at no charge.
- Access to Specific Pieces of Information (Data Portability). You also have the right to request that ManageAmerica provide you with a copy of the specific pieces of PersonalInformation that we have collected about you, including any Personal Information that we have created or otherwise received from a third party about you (a “Data Portability”request). If you make a Data Portability Personnel Request electronically, we will provide you with a copy of your Personal Information in a portable and, to the extent technically feasible, readily reusable format that allows you to transmit the Personal Information to another third party. You must specifically describe if you are making a Right to Know request or a Data Portability request. If you would like to make both a Right to KnowPersonnel Request and a Data Portability Personnel Request you must make both requests clear in your request. If it is not reasonably clear from your request, we will only process your request as a Right to Know request. We will not disclose your social security number, driver’s license number or other government-issued identification number, financial account number, health insurance or medical identification number, or your account password or security question or answers in response to a Data Portability PersonnelRequest. We will also not provide this information if the disclosure would create a substantial, articulable, and unreasonable risk to your Personal Information, your Personnel relationship with ManageAmerica, or the security of our systems or networks. We will also not disclose any Personal Information that may be subject to another exception under theCCPA. If we are unable to disclose certain pieces of your Personal Information, we will describe generally the types of Personal Information that we were unable to disclose and provide you a description of the reason we are unable to disclose it. You may make a Right to Know or a Data Portability Personnel Request a total of two (2) times within a 12-month period at no charge, although you may have other rights to access certain pieces of yourPersonal Information under applicable labor and employment laws.
- Correction. You have the right to request that we correct any incorrect PersonalInformation about you to ensure that it is complete, accurate, and as current as possible.You may review and correct some Personal Information about yourself by logging intoManageAmerica’s intranet and accessing your human resources profile page. You may also request that we correct the Personal Information we have about you as described below under Exercising Your CCPA Privacy Rights. In some cases, we may require you to provide reasonable documentation to show that the Personal Information we have about you is incorrect and what the correct Personal Information may be. We may also not be 11able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
- Deletion. You have the right to request that ManageAmerica delete any of your PersonalInformation that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your Personnel Request (see Exercising Your CCPA PrivacyRights), we will delete (and direct our service providers to delete) your PersonalInformation from our records, unless an exception applies pursuant to the CCPA. Some exceptions to your right to delete include if we are required to retain your PersonalInformation to maintain your Personnel relationship with us, to detect security incidents or protect against other malicious activities, and to comply with legal obligations. We mayalso retain your Personal Information for other internal and lawful uses that are compatible with the context in which we collected it.
- Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not do any of the following as a result of you exercising your CCPA rights: (a) deny you employment or other similar relationship as ManageAmerica Personnel; (b) provide you with different compensation, benefits, work hours, or terms of employment or other similar relationship as ManageAmerica Personnel; or (c) suggest that you may receive different compensation, benefits, work hours, or terms of employment or other similar relationship as ManageAmerica Personnel or be denied employment or other similar relationship as ManageAmerica Personnel. You may, however, receive certain discounts from benefits third-party providers for providing your Personal Information, such as discounts on health or other insurance.
Exercising Your CCPA Privacy Rights
To exercise the rights described above, please submit a request (a “Personnel Request”) to us by either:
- Calling us at 800-747-0259.
- Emailing us at privacy@manageamerica.com.
- Submitting a request via email from your ManageAmerica email account with the HumanResources department.
If you fail to make your Personnel Request in accordance with the ways described above, we may either treat your request as if it had been submitted with our methods described above or provide you with information on how to submit the request or remedy any deficiencies with your request.
Only you, or your Authorized Agent that you authorize to act on your behalf, may make aPersonnel Request related to your Personal Information. To designate an Authorized Agent, see Authorized Agents below. All Personnel Requests must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an Authorized Representative of such a person.
This may include:
- Showing your badge, if you make your request live.
- Providing other information about you (like verifying the last digits of your SSN, bank account number, or other information).
- Calling from an internal phone with call back or other similar verification (such as video).
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm which Personal Information relates to you or the individual for whom you are making the request as their Authorized Agent.
We will only use Personal Information provided in a Personnel Request to verify the requestor’s identity or authority to make the request.
Authorized Agents
You may authorize your agent to exercise your rights under the CCPA on your behalf by providing them with written permission to submit the Personnel Request on your behalf (an “AuthorizedAgent”). You may also provide your Authorized Agent with power of attorney to exercise your rights in accordance with applicable laws. We may request that your Authorized Agent submit proof of identity and that they have been authorized to exercise your rights on your behalf. We may deny a request from your Authorized Agent to exercise your rights on your behalf if they fail to submit adequate proof of identity or adequate proof that they have the authority to exercise your rights.
Response Timing and Format
We will confirm our receipt of your Personnel Request within ten (10) business days of its receipt.We will generally process these requests within forty-five (45) calendar days of its receipt. If we require more time (up to an additional calendar 45 days), we will inform you of the reason and extension period in writing.
In response to a Right to Know or Data Portability Personnel Request, we will provide you with all relevant information we have collected or maintained about you in the twelve (12) month period prior to our receipt of your Personnel Request, unless you request a longer period (no earlier than January 1, 2022) or an exception applies. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For Data Portability Personnel Requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your Personnel Request unless it is excessive, repetitive, or manifestly unfounded. We reserve the right to consider more than two (2) total Right to Know or Data Portability Personnel Requests in a twelve (12) month period to be repetitive and/or excessive and require a fee. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Your Choices Regarding our Use and Disclosure of Your Sensitive PersonalInformation
We do not use or disclose your Sensitive Personal Information for any purpose other than as described in this California Personnel Privacy Notice. The CCPA allows us to use and disclose your Sensitive Personal Information for the following purposes without providing you an opportunity to limit our use and disclosure of your Sensitive Personal Information:
- To provide the employment relationship as reasonably expected by an average consumer who wishes to have a ManageAmerica Personnel relationship with us;
- To detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted Personal Information, provided that our use of yourPersonal Information is reasonably necessary and proportionate for such purposes;
- To resist malicious, deceptive, fraudulent, or illegal actions directed at ManageAmerica and to prosecute those responsible for those actions, provided that our use of your Personal Information is reasonably necessary and proportionate for this purpose;
- To ensure the safety of natural persons, provided that our use of your Sensitive PersonalInformation is reasonably necessary and proportionate for this purpose;
- For short-term, transient use;
- To perform services on behalf of us, such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of us; and
- To verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by us.
In addition, we may also use or disclose your Sensitive Personal Information for the following purposes:
- As necessary to comply with federal, state, or local laws or comply with a court order or subpoena to provide information;
- To comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
- To cooperate with law enforcement agencies concerning conduct or activity that We may reasonably and in good faith believe may violate federal, state, or local law;
- To cooperate with a government agency request for emergency access to PersonalInformation (including Sensitive Personal Information) if a natural person is at risk or danger of death or serious physical injury; and
- To exercise or defend legal claims.
Because we only use your Sensitive Personal Information for the above purposes, we do not, and are not required to, provide you with the ability to limit the use of your Sensitive PersonalInformation for these purposes.][You may not limit the use of your Sensitive Personal Information for the above purposes.
Personal Information Retention Periods
If you are not employed by ManageAmerica, we may retain your Personal Information (other than transient information, such as emails and information in log files) for at least a period four (4)years following the date of our last action on your application. If you are retained byManageAmerica, we may retain your Personal Information (other than transient information, such as emails and information in log files) for at least the duration of your employment plus four (4)years afterwards. However, we may retain any or all categories of Personal Information when your information is subject to one of the following exceptions:
- When stored in our backup and disaster recovery systems. Your Personal Information will be deleted when the backup media your Personal Information is stored on expires or when our disaster recovery systems are updated.
- When necessary for us to exercise or defend legal claims.
- When necessary to comply with a legal obligation.
- When necessary to help ensure the security and integrity of our IT systems and to protect the rights, property, or safety of ManageAmerica, our facilities, our customers, or others.
Your Personal Information will be deleted when we no longer require your Personal Information for any of the above purposes.
Changes to This California Personnel Privacy Notice
ManageAmerica reserves the right to amend this California Personnel Privacy Notice at our discretion and at any time. When we make changes to this California Personnel Privacy Notice, we will notify you regarding the updated notice through ManageAmerica’s communication channels, including through email or paper notices, and update the addendum’s effective date.
Contact Information
If you have any questions or comments about this California Personnel Privacy Notice, the ways in which ManageAmerica collects and uses your Personal Information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, pleasedo not hesitate to contact us through the Human Resources department.
