Employee and Candidate Privacy Notice
We know that you care about how we collect, use, and store personal information about you and your privacy is important to us. We are committed to protecting and respecting your privacy. This Notice aims to provide information about how we process and protect your data.
This Privacy Notice (“Privacy Notice”) applies solely to all individuals that reside in the State of California who are job applicants, employees, directors, officers, or contractors (“Workers,” “you,” or “your”) of ScribeAmerica, or its affiliates (“us,” “our,” or “we”). This Notice complies 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 may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Worker or device (“Personal Information”). In particular, we may have collected the following categories of Personal Information from those Workers who are subject to this Notice within the last twelve (12) months:
The following are categories and examples of the type of personal information we may collect concerning you, although not all of the categories and examples of personal information listed below will apply to you all of the time:
- Identifiers and demographic data. This includes data like name, address, email, marital status, birth date, gender, educational data, etc.
- Sensitive Data. This includes data like financial account numbers, SSN, medical data, vaccination status, biometric data, performance reviews, etc.
- Transactional Data. This includes data you may share with us when you are acting in your capacity as a consumer instead of an employee.
- Biometric information. This includes information like ID badge photos, fingerprints used with time keeping systems, or security camera video footage of you.
- Internet or other similar network activity. You use our systems every day for your work. All the activity you have on these systems, from email to web browsing, is collected and used. This includes log-in details, software application usage, VoIP phone usage, and file share access.
- Geolocation data. This can include location data we may collect as part of your use of a smart phone issued by us, or GPS data collected when you use one of our vehicles.
- Sensory data. This is data which may or may not be related to you directly, as it is usually data coming from devices like security motion detectors or similar devices, as well as easily observable physiological information such as face or body temperature. However, if it is tied to other data, like key card access logs, it can become personal information.
- Professional or employment-related information. This is all the data related to your employment with us, including but not limited to Personal Information related to individuals who receive benefits from us as a result of your status as a Worker with us. For example, it can include “right to work” documents, payroll and benefits data, medical leave data, or other kinds of information necessary for us to acquire, manage, and retain talent in our workforce.
- Non-public education information. This is information related to your academic credentials such as what school you went to, what your GPA was, what activities or sports you did in school, or other data on your school transcripts.
- Inferences based on Personal Information. This includes information in performance reviews, any testing you may have undertaken, information related to succession planning, as well as predictive analytics related to your use of our IT systems and networks.
Personal Information does not include:
- Publicly available information from government records.
- Deidentified or aggregated information.
- Information excluded from the CCPA’s scope
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase (if any).
- Indirectly from you. For example, from observing your actions as a Worker, from records of your use of our information technology, or from location-tracking enabled devices connected to our assets you may use as part of your regular employment related activities with us.
- From independent third parties related to your eligibility for employment, or our ongoing management of our business.
- Other Workers, as part of our management, evaluation, training, and discipline processes.
Use of Personal Information
We may process or disclose the Personal Information we collect for one or more of the following business purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to apply for a job with us, or request vacation time, or in order to administer benefits, or to process payroll.
- To provide, support, personalize, and develop our Worker population.
- To managing the health and welfare risks (e.g. pandemic management) to our Workers, our clients, and the population generally.
- To provide you with support and to respond to your inquiries.
- 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.
- Disclosures made in an effort to prevent or halt violations of our policies, illegal activities, or as required by law.
- Disclosures that we reasonably believe are necessary to defend against or prevent us from incurring liability to third parties.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
We 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.
Sharing Personal Information
We are part of a group of companies where certain services are provided centralized by one or more affiliates for the entire group or a part of it. We, therefore, reserve the right to share Personal Information with our direct and indirect affiliates for all purposes described above. Whenever we share Personal Information with our affiliates, we request from them that they commit themselves to process Personal Information in line with this Notice only.
We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. These third parties are “Service Providers” as defined by applicable law.
We may also disclose your Personal Information to another company as part of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets to that company; or where required by our policy, law, or in response to valid legal process compelling disclosure.
We disclose your Personal Information for a business purpose only to Service Providers, or, where required by law, or in response to valid legal process compelling disclosure.
Sales of Personal Information
We do not sell Personal Information or share Personal Information with any third parties who are not Service Providers, where we may receive a financial benefit from such sharing.
If you have any questions or comments about this notice, the ways in which we collect and use your information, please do not hesitate to contact either your HR representative, our Privacy Officer, or our Legal Department at:
Legal Department, Attn: Privacy
1200 East Las Olas Boulevard, Suite 301
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This Notice is effective as of January 1, 2022. Applicable privacy laws change, and accordingly, this Notice may also change. Any changes that we do make to this Notice are not intended to make our practices less protective of any of your Personal Information that we have previously collected. You should check this Notice frequently to see recent changes. Unless stated otherwise, our current Notice applies to all Personal Information that we have about you.