Privacy Notice for California Employees and Job Applicants

This Privacy Notice for California Employees and Job Applicants supplements the information contained in other personnel disclosures and applies solely to all employees or job applicants who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information from our employees, and job applicants that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, ICW Group has collected the following categories of personal information from its employees or job applicants within the last twelve (12) months:

Category Examples1 Collected Sources Purpose Third Parties Shared
A. Identifiers Real 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 Directly or indirectly from you Necessary for our legitimate interests

Necessary to comply with a legal obligation

Human Resources information service providers

Financial investment service providers

Wellness program service providers

Insurance providers

Payroll service providers

B. 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 card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. Yes Directly or indirectly from you

From third parties

Necessary for our legitimate interests

Necessary to comply with a legal obligation

Human Resources information service providers

Financial investment service providers

Wellness program service providers

Insurance providers

Payroll service providers

Government Entities

C. California or Federal Protected Classifications Age (40 years or 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 (including familial genetic information). Yes Directly or indirectly from you Necessary for our legitimate interests

Necessary to comply with a legal obligation

Human Resources information service providers

Insurance providers

Payroll service providers

Government entities

D. Commercial Information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. No
E. Biometric Information Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. Yes Directly or indirectly from you

From third parties

Necessary for our legitimate interests Wellness program service providers
F. Internet or other Electronic Network Activity Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Yes; when using Company resources Directly or indirectly from you

From third parties

Necessary for our legitimate interests
G. Geolocation Data Physical location or movements. Yes Directly or indirectly from you

From third parties

Necessary for our legitimate interests
H. Sensory Data Audio, electronic, visual, thermal, olfactory, or similar information. Yes Directly or indirectly from you Necessary for our legitimate interests
I. Professional or employment-related information Employment records Yes Directly or indirectly from you

From third parties

J. Non-Public Education information defined by FERPA. Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Yes Directly or indirectly from you Necessary for our legitimate interests
K. Inferences drawn from any of the information listed above. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Yes Directly or indirectly from you

From third parties

Necessary for our legitimate interests

1 Examples listed herein are illustrative of the types of personal information included in each category and may or may not be the specific types of personal information collected on an individual employee or job applicant. Additionally, some personal information included in the categories may overlap with other categories.

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

ICW Group obtains the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete.
  • Indirectly from you. For example, from observing your interactions with company systems or our products or services.
  • Third Parties. For example, from vendors used for background checks.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, to conduct payroll and timekeeping activities, administer benefits, or to apply for employment or promotion.
  • To investigate and help prevent fraud or otherwise ensure compliance with law, regulation, policies and procedures.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To help maintain the safety, security, and integrity of our systems, services, databases and other assets.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of ICW Group’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by ICW Group about our users is among the assets transferred.

ICW Group will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Changes to This Privacy Notice

  • ICW Group reserves the right to amend this privacy notice at our discretion and at any time.
  • When we make changes to this privacy notice, we will post the updated notice and update the notice’s effective date.
  • Last updated on June 21, 2021

Questions about This Privacy Notice

If you have any questions or comments about this notice or the ways in which ICW Group collects and uses your information, please email dataprivacy@icwgroup.com. For more information about ICW Group privacy practices please see our Legal Notice & Privacy Policy.