CALIFORNIA CONSUMER PRIVACY RIGHTS ACT (CPRA)
NOTICE TO APPLICANTS AND EMPLOYEES
Please take notice that Trust Automation and Trust Children’s Center(“Company”) collects certain personal information about you. This Notice describes the categories of personal information the Company collects and the purposes for which they are used in accordance with the California’s California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”).
The law provides California applicants and employees with certain rights with respect to the personal information collected from them, including the right:
- To delete personal information.
- To correct inaccurate personal information.
- To access personal information.
- To know what personal information is sold or shared and to whom.
- To opt out of selling or sharing of personal information.
- To limit use and disclosure of sensitive personal information.
- Not to be discriminated or retaliated against for exercising rights under the law.
The Personal Information That We Are Collecting. We are collecting the following personal information:
- Identifiers, such as name, government-issued identifier (e.g., Social Security number), and unique identifiers (e.g., employee ID);
- Personal information, such as real name, signature, SSN, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, passport number, federal identification authorizing work in the United States, access and/or passcodes, insurance policy number, education, employment, employment history, bank account number, other financial information, medical information, or health insurance information;
- Characteristics of protected classifications under California or federal law, such as age, marital status, gender, sex, race, color, disability, citizenship, primary language, immigration status, military/veteran status, disability, request for leave, and medical conditions;
- Commercial information, such as transaction information and purchase history (e.g., in connection with travel or other reimbursements or purchases from Company);
- Internet or network activity information, such as browsing history and interactions with our online systems and websites;
- Geolocation data, such as device location from usage of the Company’s devices;
- Biometric information related to access to the Company’s secured access points;
- Audio, electronic, visual, and similar information;
- Professional or employment-related information, such as work history and prior employer;
- Non-public education information;
- Inferences drawn from any of the personal and sensitive personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
Personal information does not include:
- Publicly available information from government records.
- 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.
The Company does not currently employ, or anticipate employing, anyone under 16 years of age, the Company does not collect any personal information related to anyone under 16 years of age.
Where We Get Your Information From. The Company collects information about you from the following sources:
- You;
- Prior employers, references, recruiters, job-related social media platforms;
- Third-party sources of demographic information;
- Third-party companies, such as background check companies, drug testing facilities, licensing and credentialing organizations;
- Claim administrators and investigators.
Depending on Company’s interactions with you, the Company may or may not collect all of the information identified about you.
How Your Personal Information is Used. We may use personal information for the following purposes:
- Recruiting and retaining employees.
- Collecting and processing employment applications, including confirming eligibility for employment, background and related checks, and onboarding.
- Employee benefit plan and program administration.
- Leave of absence administration.
- Compensation administration and compliance, including payroll, bonuses, reimbursements, etc.
- Maintaining personnel records and complying with record retention requirements.
- Communicating with employees and/or employees’ emergency contacts and plan beneficiaries.
- Facilitating and administering the use of Company’s property and resources, including Company’s information systems, electronic devices, network, and data, and preventing unauthorized access of such.
- Workplace health and safety compliance.
- Ensuring employee productivity and adherence to the policies.
- Investigating complaints, grievances, and suspected violations of policy.
- Complying with applicable state and federal laws, including labor, employment, tax, benefits, workers compensation, disability, equal employment opportunity, workplace safety and related laws.
- Exercising and defending legal claims.
- Any other purposes authorized by the California Privacy Protection Agency, California law, or federal law.
The Company may or may not have used personal information about you for each of the above purposes.
The Company will retain your personal information no longer than is reasonably necessary to comply with the business or commercial purposes stated above or as required by law.
Sharing of Personal Information. The Company may share personal information with third parties in connection with the performance of our services and business operations, as permitted or required by applicable law. For example, we work with third parties that provide services to us and partner with third parties to develop, operate, deliver, maintain, improve, enhance, and protect our services and in connection with other operations. Those parties can include, but are not limited to:
- Website hosting or information technology consulting service providers;
- Data analysis service providers;
- Legal service providers;
- Accounting service providers;
- Administrative service providers;
- Security service providers;
- Application service providers;
- Benefits providers;
- Occupational health providers;
- Insurance providers;
- Travel service providers;
- Payroll service providers;
- Telecommunications and messaging services.
We may also disclose your personal information for other purposes permitted by law such as to:
- Comply with applicable laws;
- Respond to governmental inquiries or requests;
- Comply with valid legal or administrative processes.
The Company does not sell any personal information the third parties.
Employee Rights Related to Personal Information. The CCPA and CPRA provides consumers with specific rights related to their personal information collected by a business. This section describes those rights and explains how to exercise those rights.
Access and Data Portability Rights. You have the right to request that the Company disclose certain information about its collection and use of your personal information over the past 12 months. Once the Company receive and confirms a verifiable consumer request, the Company will disclose:
- The categories of personal information collected about you.
- The categories of sources for the personal information collected about you.
- The business or commercial purpose for collecting your personal information.
- The categories of third parties with whom we shared your personal information.
- The specific items of personal information collected about you.
- If the Company disclosed your personal information for a business purpose, a list identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights. You have the right to request that the Company delete any of your personal information that Company has collected and retained, subject to certain exceptions. Once the Company receives and confirms a verifiable consumer request, Company will delete your personal information from its records, unless an exception applies.
Specifically, we may be unable to delete personal information if retaining the information is necessary to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights. To exercise your access, data portability, and deletion rights described above, please submit a verifiable consumer request to the Company by one of the following methods:
Email: hr@trustautomation.com
Mail: Trust Automation Human Resources
125 Venture Drive, Suite 110
San Luis Obispo, CA 93401
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your personal information. A parent or guardian may make a verifiable consumer request related to a minor’s personal information.
Non-Discrimination. The Company will not discriminate against an Employee for exercising any of their CCPA or CPRA rights.
Contact Information If you have any questions or comments about this Notice, the ways in which we collect and use your personal information, please do not hesitate to contact us at:
Email: hr@trustautomation.com
Mail: Trust Automation Human Resources
125 Venture Drive, Suite 110
San Luis Obispo, CA 93401