Privacy Information for California Employees, Contractors, and Applicants
We collect Personal Information from current and past employees (‘Employees’), Contractors and Applicants and comply with the California Consumer Privacy Act and related laws and regulations (“California privacy laws”). This California HR Privacy Notice applies to California Employees, Contractors, and Applicants (“you” or “your”).
“Personal Information” means information that is linked or reasonably linkable to a particular individual or household. However, the following categories of information are not Personal Information:
- Publicly available information;
- Deidentified or aggregated data; or
- Information otherwise excluded from the scope of California privacy laws.
This Privacy Notice provides the following information to California Employees, Contractors, and Applicants:
- Categories of Personal Information we collect;
- Purposes for which we use Personal Information;
- Categories of Personal Information we disclose to third parties;
- Categories of third parties to which we disclose Personal Information; and
- How Employees, Contractors, and Applicants can exercise their rights under California privacy laws:
- The rights to access, correct, or delete Personal Information;
- The right to limit the use of sensitive Personal Information in certain circumstances; and
- The rights to opt out of targeted advertising, sales of Personal Information, or profiling.
Categories of Non-Sensitive Personal Information
The table below outlines the non-sensitive categories of Personal Information Holthouse Carlin & Van Trigt LLP collects about Employees, Contractors, and Applicants and whether and how they are disclosed to third parties.
We collect Non-Sensitive Personal Information from the following sources:
- Directly from our Employees, Contractors, and Applicants
Category of Personal Information: Identifiers
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Examples
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Identifiers may contain the following: names, addresses, social security numbers, etc.
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Purpose(s)
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To process payroll, perform background checks, and comply with statutory obligations.
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Targeted Advertising
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We do not engage in targeted advertising or disclose this information for targeted advertising purposes.
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Sale
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This information is not sold to third parties.
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Other Disclosures
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This information may be disclosed to Processors. We disclose Identifiers to enable our processors to provide services on our behalf.
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Retention Period
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In accordance with our data retention policy, professional standards, and as required by law.
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Category of Personal Information: Personal Characteristics
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Examples
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Personal Characteristics may contain the following: age.
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Purpose(s)
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To process payroll, perform background checks, and to comply with statutory obligations.
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Targeted Advertising
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We do not engage in targeted advertising or disclose this information for targeted advertising purposes.
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Sale
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This information is not sold to third parties.
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Other Disclosures
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This information may be disclosed to Processors. We disclose Personal Characteristics to enable our processors to provide services on our behalf.
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Retention Period
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In accordance with our data retention policy, professional standards, and as required by law.
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Category of Personal Information: Internet/Electronic Activity
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Examples
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Internet/Electronic Activity may contain the following: browsing history, app use, device ID, etc.
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Purpose(s)
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Specific to employees and contractors, to access to our environment to maintain reasonable security measures.
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Targeted Advertising
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We do not engage in targeted advertising or disclose this information for targeted advertising purposes.
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Sale
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This information is not sold to third parties.
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Other Disclosures
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This information may be disclosed to Processors. We disclose Internet/Electronic Activity to enable our processors to provide services on our behalf.
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Retention Period
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In accordance with our data retention policy, professional standards, and as required by law.
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Category of Personal Information: Professional Information
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Examples
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Professional Information may contain the following: employment history.
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Purpose(s)
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To screen individuals as part of our recruiting processes.
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Targeted Advertising
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We do not engage in targeted advertising or disclose this information for targeted advertising purposes.
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Sale
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This information is not sold to third parties.
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Other Disclosures
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This information may be disclosed to Processors. We disclose Professional Information to enable our processors to provide services on our behalf.
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Retention Period
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In accordance with our data retention policy, professional standards, and as required by law.
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Category of Personal Information: Educational Information
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Examples
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Educational Information may contain the following: school transcripts.
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Purpose(s)
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To screen individuals as part of our recruiting processes.
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Targeted Advertising
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We do not engage in targeted advertising or disclose this information for targeted advertising purposes.
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Sale
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This information is not sold to third parties.
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Sharing
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This information may be disclosed to Processors. We disclose Educational Information to enable our processors to provide services on our behalf.
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Retention Period
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In accordance with our data retention policy, professional standards, and as required by law.
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Categories of Sensitive Personal Information
The table below outlines the categories of Sensitive Personal Information Holthouse Carlin & Van Trigt LLP collects about Employees, Contractors, and Applicants and whether they are disclosed to third parties.
We collect Sensitive Personal Information from the following sources:
- Directly from our Employees, Contractors, and Applicants
Category of Sensitive Personal Information: Government ID Data
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Examples
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Government ID Data may contain the following: social security number, driver’s license number, state identification card, passport number, or similar government ID.
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Purpose(s)
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To process payroll, perform background checks, and to comply with statutory obligations.
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Targeted Advertising
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We do not engage in targeted advertising or disclose this information for targeted advertising purposes.
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Sale
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This information is not sold to third parties.
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Other Disclosures
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This information may be disclosed to Processors. We disclose Government ID Data to enable our processors to provide service on our behalf.
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Retention Period
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In accordance with our data retention policy, professional standards, and as required by law.
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Category of Sensitive Personal Information: Sensitive Category Data
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Examples
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Sensitive Category Data may contain the following: social security number, driver’s license number, state identification card, passport number, or similar government ID.
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Purpose(s)
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To process payroll, perform background checks, and to comply with statutory obligations.
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Targeted Advertising
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We do not engage in targeted advertising or disclose this information for targeted advertising purposes.
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Sale
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This information is not sold to third parties.
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Other Disclosures |
This information may be disclosed to Processors. We disclose Sensitive Category Data to enable our processors to provide services on our behalf.
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Retention Period
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In accordance with our data retention policy, professional standards, and as required by law.
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Use of Personal Information
We use Personal Information for the purposes described above. Other examples of how we may use your Personal Information within Holthouse Carlin & Van Trigt LLP include:
- Publishing Employees’ work contact information in an intra-company directory for other Employees to view.
- Disclosing applicants’ submitted Personal Information with our HR department and other employees to process applications.
- Creating profiles of contractors’ performance based on work product.
Personal Information may also be used or disclosed as otherwise permitted or required by applicable law.
Disclosing Personal Information
We disclose Personal Information to the following categories of third parties:
- Processors (also referred to as “Service Providers” or “Contractors” in California law): We use processors to securely handle Personal Information on our behalf for our business purposes and only on our instructions. California privacy laws and our contracts with these companies prevent them from using your Personal Information for their own purposes.
- Other Employees, Contractors, and Applicants: Content you post on our systems may be displayed to other Employees, Contractors, and Applicants as appropriate.
See the tables above for more details about how different categories of Personal Information are disclosed.
We do not sell Personal Information to anyone. We do not share Personal Information for advertising purposes.
Exercising Your Personal Information Rights
California Employees, Contractors, and Applicants have the following rights under California privacy laws:
- The right to know the Personal Information we have collected about them, including the categories of sources from which we collected the Personal Information, the purpose(s) for collecting, selling, or sharing your Personal Information, and the categories of third parties to whom we have disclosed your Personal Information
- The rights to correct, or delete Personal Information;
- The right to limit the use of Sensitive Personal Information in certain circumstances;
- The rights to opt out of targeted advertising, sales of Personal Information, or profiling; and
- The right not to receive discriminatory treatment for exercising their privacy rights.
If you are a California Employee, Contractor, or Applicant, you can submit a request to exercise your Personal Information rights under California privacy law by visiting our online HR Privacy Request portal at https://www.requesteasy.com/63d4-5308 or calling our toll-free number at 1-855-435-9352.
To protect your privacy, we may need to authenticate your identity before we respond to your rights request. We will verify your identity by sending an email to the email address on file with a link to click. We may ask you for additional information as part of this process, including the last 4 digits of your social security number. If you do not complete the verification process, we may be unable to process your request. Any information you provide to authenticate your identity will only be used to process your rights request and not for any other purpose. Please be aware that we do not accept, or process rights requests submitted through other means.
We will respond to your rights request within 45 days, though in certain cases we may inform you that we will need up to another 45 days to act on your request. If we suspect fraudulent or malicious activity on or from your account, we will delay taking action on your request until we can appropriately verify your identity and the request as authentic. Also note that each of the rights are subject to certain exceptions.
We reserve the right to decline to process, or charge a reasonable fee for, requests from an Employee, Contractor, or Applicant that are manifestly unfounded, excessive, or repetitive.
Notice of Right to Limit the Use of Sensitive Personal Information
You have the right to limit some uses of Sensitive Personal Information. You may direct companies not to use Sensitive Personal Information except as necessary to provide goods or services you have requested or other exempt purposes.
However, we only use Sensitive Personal Information for purposes that are exempt from this right, such as to provide you with goods or services you have requested, to detect and prevent security incidents, or verifying the quality of our goods and services. The full list of these exempt purposes is specified in California Code of Regulations, Title 11, Section 7027(m).
Children’s Data
We do not knowingly collect or use the Personal Information of children under 16. If you believe that we have collected the Personal Information of a child under 16, please contact us at HRPrivacy Request@hcvt.com.
Authorized Agent Requests
California privacy law allows you to designate an authorized agent to make a rights request on your behalf. Your authorized agent may submit such a request by following the same method described above. We may require verification of your authorized agent in addition to the information for verification above for Employees, Contractors, and Applicants and households.
Contact Us
If you have any questions or concerns regarding this California HR Privacy Notice, contact us at HRPrivacy@hcvt.com.
Last updated: August 7, 2023