Effective January 1, 2023
R&R Partners, Inc. (“R&R,” “Company,” “we”, “us” or “ours”) adopts this California Consumer Protection Act Employee and Applicant Privacy Notice (“Notice”) to comply with the California Consumer Privacy Act as amended by the California Privacy Rights Act (together “CCPA”) and to describe how R&R processes Personal Information (“PI”). This Notice applies to all job applicants, employees, owners, directors, officers, and contractors who reside in the State of California (“California Workers”). Capitalized terms used but not defined in this Notice shall have the meaning given to them under CCPA.
We may collect your PI directly from you, such as when you apply for a position or become employed or engaged by us (e.g., identification/identity data, contact details, educational and employment data), over the phone or through paper documents such as applications for employment and consents to perform employment screening, in our notes or records we create about you, from others through interactions in the course of employment or engagement, from third parties (e.g., references and recruiters), or from public sources of data.
- “Personal Information” has the meaning as defined in the CCPA and includes information that is collected by R&R about you in the course of your application for employment, direct services pursuant to a contract, or other employment-related purposes and encompasses any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.
- “Process,” “processed” or “processing” means any operation or set of operations which is performed on PI, whether or not by automated means, such as collecting, recording, organizing, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, disseminating or otherwise making available, aligning or combining, restricting, erasing, or destroying of Personal Information.
- “Employees,” “employee” or “you” means an identified or identifiable natural person who is a California resident and who is acting as an R&R job applicant, employee, owner, director, officer, or contractor. In this context “job applicant” refers to any person who has submitted their candidacy with R&R; “employee” refers to any person who is employed at R&R as a full or part-time employee or temporary worker; and “contractor” means a natural person who provides any service to R&R pursuant to a written contract directly with R&R.
B. CATEGORIES OF PI
The chart below identified categories and examples of PI and Sensitive Personal Information covered by CCPA, some of which R&R collects:
|Category of PI||EXAMPLES||COLLECTED|
|Identifiers||Identifiers, such as name, alias, online identifiers, account name, address, email address, passport number, social security number, driver’s license number, physical characteristics or description, and other similar identifiers.||Yes|
|Personal information categories listed in the California Customer Records Statute||Contact and financial information, including phone number, address, email address, financial information, medical information, health insurance information.||Yes|
|Protected classifications under California law||Characteristics of protected classifications under state or federal law, such as age, gender, race, physical or mental health conditions, and marital status.||Yes|
|Commercial Information||Records of personal property, products, or services purchased.||No|
|Biometric Information||Physiological, behavioral, and biological characteristics, including DNA, that is or intended to be used either alone or in combination with other identifying data to establish individual identity, and includes other identifying information, such as, imagery of the iris or retina, fingerprint, face, hand, palm, vein paterns and voice recordings from which an identifier template or a voice print can be extracted, also includes, keystroke or gait paterns or rhythms, and sleep, health, or exercise data that contain identifying information.||No|
|Internet or other similar activity||Browsing history, search history, information on a consumers’ interaction with a website, application or advertisement.||Yes|
|Geolocation data||Physical location or movements.||Yes|
|Sensory data||Audio, electronic, visual, and similar information, such as call and video recordings.||No|
|Professional or employment related data||Current or past job history or performance evaluations.||Yes|
|Education information, as defined in the federal Family Educational Rights and Privacy Act, such as student records and directory information||Education records directly related to a student maintained by an educational institution or party acting on its behalf such as grades and transcripts.|
|Inferences drawn from other personal information||Profile reflecting a person’s preferences characteristics, psychological trends, predispositions, behavior attitudes, intelligence, abilities, and aptitudes.||Yes|
|Sensitive personal information||Personal information that reveals a person’s: social security, driver’s license, state identification card or passport number, precise geolocation, race or ethnic origin, religious or philosophical beliefs, contents of a person’s mail, email and text messages unless the business is the intended recipient; Personal Information Collected and analyzed concerning a Consumer’s health. Note: Sensitive personal information does not include information that is “publicly available” as defined in 1798.140(v)(1)(L).||Yes|
C. PURPOSES FOR WHICH R&R WILL USE YOUR PI
- To evaluate your eligibility or suitability for any type of engagement or association with R&R, or your eligibility or suitability for employment, including but not limited to confirming employment, educational, and military histories when applicable;
- Perform background checks and verify past employment, educational history, professional standing, and other qualifications;
- Evaluate, determine, and arrange compensation, payroll, and benefits;
- Assess your fitness and physical capacity for work;
- Contact you regarding your application and potential Employee relationship with us;
- Manage your Employee relationship with us;
- Manage and provide compensation, payroll, tax, expense reimbursement, and benefits planning, enrollment, and administration;
- To evaluate and permit your participation in any retirement plan offered by R&R in which you are eligible to participate under the terms of that plan and to administer your participation in and payments made to or from any plan;
- To evaluate or administer any type of benefits offered by R&R for which you or a family member may be eligible, and to pay and or dispute claims;
- To communicate with you or a related third party such as our insurer, any benefits or claims administrator or your agent, broker or a claim administrator about the status, developments or the outcome or our legal analysis of any claim or dispute;
- Provide you access to R&R systems, networks, databases, equipment, and facilities;
- Manage our workforce and its performance, including personnel planning, productivity monitoring, and evaluation;
- Manage workforce development, education, training, and certification;
- For possible inclusion in any affirmative action programs including programs for veterans or individuals with disabilities;
- Monitor, maintain, and secure R&R systems, networks, databases, equipment, and facilities;
- Authenticate your identity and verify your access permissions;
- Arrange, confirm, and monitor work-related travel, events, meetings, and other activities;
- To respond for requests for proposals (“RFPs”), to highlight your knowledge, background, experience for marketing purposes, for making pitches to clients, to respond to client inquires or questionnaires, or in business development and marketing efforts to attract new clients or business and/or to retain existing clients and business;
- Assess your working capacity or the diagnosis, treatment, or care of a condition impacting your fitness for work, and other preventative or occupational medicine purposes (including work-related injury and illness reporting);
- Contact and communicate with you regarding your employment, job performance, compensation, and benefits, or in the event of a natural disaster or other emergency;
- Contact and communicate with your designated emergency contact(s) in the event of an emergency, illness, or absence;
- Contact and communicate with your dependents and designated beneficiaries in the event of an emergency or in connection with your benefits;
- For any other lawful purpose necessary to further the legitimate interests of R&R; and
- For any purpose related to the foregoing.
In addition to the purposes identified above, R&R may use and disclose any and all PI 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 R&R 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 R&R and its employees, affiliates, customers, contractors, and agents.
Please note: 1) We do not and will not sell your PI; 2) We will not share your PI with third parties for cross-context behavioral advertising purposes; and 3) We will not use your PI to make any automated decisions affecting you.
C. CATEGORIES OF THIRD PARTIES WITH WHOM WE MAY SHARE YOUR PERSONAL DATA
- Affiliates & Service Providers. We may disclose Applicant and Employee PI to our affiliates and Service Providers for the purposes described in Sections B of this Notice. Our Service Providers provide us with Applicant selection and related hiring services, benefits and wellness services, website services, as well as other products and services, such as web hosting, data analysis, customer service, infrastructure services, technology services, email delivery services, legal and financial services, and other similar services. We grant our Service Providers access to 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 PI to the following categories of Third Parties:
- At Your Direction. We may disclose your PI to other Third Parties with your consent or at your direction.
- Business Transfers or Assignments. We may disclose your PI to other entities as reasonably necessary to facilitate 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 PI 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 permited or required by law.
D. OTHER DISCLOSURES
- Protection & Retention of Personal Information: R&R processes your PI for the period necessary to fulfill the purposes outlined in this Notice and to preserve your PI in accordance with the provisions of relevant laws and regulations. The PI you provide to us may be held and stored electronically and/or in hard copy. R&R implements appropriate technical and organizational security measures, to protect against and detect accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to Personal Information.
R&R employees and Service Providers that have access to your PI are bound by strict confidentiality obligations and are required to treat your PI in accordance with legal requirements. In addition, depending on the information or purpose for Collection, only R&R employees and Service Providers who have a “need to know” your information will be permitted to access it.
- 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. For example, we will not make hiring, firing, promotion, or disciplinary decisions based on or in consideration of your exercise of your data subject rights.
- Changes to this Notice. We reserve the right to amend this Notice at our discretion and at anytime. When we make material changes to this Notice, we will notify you by posting an updated Notice on our website and listing the effective date of such updates.
- Contact Us: For general questions about this Notice, you may contact us as follows:
Office of General Counsel
R&R Partners, Inc.
900 South Pavilion Center Dr.
Las Vegas, NV 89144
- Exercising Data Subject Rights. Applicants and Employees may exercise your data subject rights by contacting email@example.com or 833-431-0742