CCPA Notice

 

THE COOK AND BOARDMAN GROUP

EMPLOYEE PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Effective Date:  February 1, 2024

The Cook and Boardman Group, LLC (the “Company”) provides this Employee Privacy Notice For California Residents (“Notice”), which applies to employees, independent contractors, and other individuals who interact with the Company in an employment-related capacity (collectively, “employees”) and that are California residents.  The Company respects the privacy of our employees and of every individual whose personal data we handle and are committed to the responsible management, use, and protection of personal information. This Notice sets forth our privacy practices as required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and its implementing regulations (collectively, the “CCPA”) and explains how the Company collects, uses, and discloses your personal information for purposes of managing your employment relationship with us and your rights under the CCPA.  Any terms defined in the CCPA have the same meaning when used in this Notice. 

Please read this Notice carefully to understand our practices regarding your personal information and how we will treat it.  If there are any material changes to this Notice, we will notify you as required by applicable law. 

If you have questions or concerns regarding this Notice, please contact HR@cookandboardman.com.

When we say “personal information” in this Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. The personal information that we collect, use, or disclose about you will depend on our relationship or interaction with you.  During the past twelve (12) months, we may have collected the following categories of personal information. Please note that some of the data collection and uses described below may not apply to you.

Sensitive personal information is a subtype of personal information under the CCPA consisting of specific information categories. While we collect information that falls within the sensitive personal information categories listed in the table below, the CCPA does not treat this information as sensitive because we do not collect or use it to infer characteristics about a person.

Collection of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from your responses to information sought in your employee onboarding paperwork or forms you complete.
• Indirectly from you. For example, from your activities on Company-provided software, including email accounts and computers, among other things.
• Other. For example, staffing and recruiting agencies with whom we contract for services and consumer reporting agencies when we perform employee background screenings.    

Use of Personal Information

In addition to the purposes identified above, we collect personal information from you to use or disclose as appropriate to:  (a) comply with all applicable laws and regulations; (b) conduct employment related screenings and determine your suitability for employment-related positions; (c) engage in corporate transactions requiring a review of human resource records, such as evaluating potential mergers and acquisitions; (d) perform analytics and benchmarking, including for our diversity programs; (e) conduct internal audits and investigations; (f) investigate and enforce compliance with potential breaches of our policies and procedures; (g) administer and maintain our operations; (h) exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents; and (i) for any other lawful purpose to further the Company’s legitimate interests.

How We Disclose Personal Information

We may disclose your personal information to our service providers, who may collect or process your information on our behalf for a particular business purpose relating to our HR functions. We grant our service providers access to personal information to the extent needed for them to perform the specific services on our behalf.

Generally, we do not sell, share, or disclose employee personal information, including any sensitive personal information, to third parties.  However, we may disclose your personal information to the following categories of third parties:

• At your direction.  We may disclose your personal information to any third party with your consent or at your direction.
• Business transfers or assignments.  We may disclose your personal information to other entities as reasonably necessary to facilitate or evaluate a merger, sale, joint venture or collaboration, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock, including in connection with any bankruptcy or similar proceedings.
• Legal and regulatory.  We may disclose your personal information to government authorities, including regulatory agencies and in court proceedings, as reasonably necessary for our business operation purposes, to assert and defend legal claims, and otherwise as permitted or required by law.

Your Rights and Choices

If you are a California resident, the CCPA provides you with specific rights regarding your personal information.  This section describes your CCPA rights, when we receive your verifiable request, including the following: right to know, right to access, right to delete, and right to correct.

Right to Know - Categories Request

You have the right to request, twice in a 12-month period, the following information about the personal information we have collected about you during the past 12 months:

• The categories of personal information we have collected about you;
• The categories of sources from which we collected the personal information;
• Our business or commercial purposes for which we collected, sold, or shared the personal information;
• The categories of third parties to whom we sold or shared the personal information, by category or categories of personal information for each category of third parties to whom the personal information was sold or shared;
• The categories of personal information about you that we disclosed for a business purpose, and the categories of persons to whom we disclosed that information for a business purpose.

Right to Know - Specific Pieces

You have the right to request a transportable copy of the specific pieces of personal information we collected about you in the 12-month period preceding your request.  Please note that personal information is retained by us for various time periods, so there may be certain information that we have collected about you that we do not retain for a 12-month period and thus, it would not be able to be included in our response to you.  Also, under the CCPA, you may be limited to a certain number of “right to know” requests in any 12-month period.

Right to Delete

You have the right to request that we delete certain personal information that we collected from you.  Please understand that we cannot delete personal information in those situations where our retention is required for our own internal business purposes or otherwise permitted by the CCPA (such as fraud prevention or legal compliance).  When we receive and confirm your verifiable consumer request, we will delete your personal information from our records, unless an exception applies.

Right to Correct

You have the right to request that we correct inaccuracies that you find in your personal information maintained by us.  Once we receive and confirm your verifiable consumer request, we will use commercially reasonable efforts to correct any inaccurate information and we will instruct our service providers or any contractors to correct such information.  We will also inform you whether or not we have complied with your request, including any basis for denial of the request.

None of the above rights are absolute and requests may be denied or limited by the Company.  Such requests will be considered against all legal or regulatory requirements and privacy considerations concerning the identity or the personal information of other persons, and business considerations including but not limited to the protection of intellectual property or trade secrets, and certain Human Resources records (e.g., investigation and organizational records).  Requests may also be limited or denied depending on the technological capabilities and/or limitations of the applicable systems.

We will not discriminate against you for exercising any of your data subject rights and do not charge a fee to process or respond to your requests unless it is excessive, repetitive, or manifestly unfounded.

How to Submit Your Request

Under the CCPA, certain requests you submit to us are subject to an identity verification process (“verifiable request”) to ensure that it is you that is making the request.  We will review the information you provide as part of your request and may ask you to provide additional information via email or other means as part of this verification process.  To complete the request, you may send an email  us at HR@cookandboardman.com with subject line “California Data Request” or by calling us at (336)768-8872.

Only you or a person registered with the appropriate governmental authority that you authorize to act on your behalf may make a verifiable request related to your personal information.  If you submit a request on behalf of another person, we may require proof of authorization and verification of identity directly from the person for whom you are submitting a request.

Help

If you have questions regarding this Notice or wish to exercise your rights under the CCPA, please contact us at HR@cookandboardman.com with subject line “California Data Request” or by calling us at (336)768-8872.