CCPA Workforce - Potential, Current, and Former Employees Privacy Disclosure
Last Updated on September 29, 2024
This Privacy Disclosure (“Disclosure”) outlines how RWM manages Personal Information for job applicants, as well as current and former employees (collectively referred to as “Personnel”) in relation to employment functions. Please note that this Disclosure does not cover Personal Information about other individuals or information collected in different contexts. For instance, if you engage with our commercial or job applicant websites, the RWM California Consumer Privacy Disclosure and/or the privacy disclosure specific to that website will apply instead.
Updates: We may revise this Disclosure periodically. Any updates will take effect upon posting. We encourage you to review this Disclosure regularly for any changes. If required by law, we will notify you directly about any updated Disclosure.
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We gather Personal Information about you from various sources, including:
A. Directly from You: We collect Personal Information you provide directly, such as when you apply for a job, register for benefits, sign up for events, or give feedback—throughout your interactions with us before, during, and after your employment.
B. Automatically and Through Tracking Technologies: We may automatically collect information about your activities, such as how you browse the internet using Company devices and systems or how you send and receive emails.
C. From Third Parties: We may obtain information from independent recruitment partners, including background check results, where permitted by law.
D. From Service Providers: We may collect information on our behalf from service providers.
E. From Colleagues and Affiliates: Personal Information may also come from your coworkers or supervisors, particularly in relation to performance evaluations.
F. From RWM Representatives: We may receive information from representatives like agents and brokers.
G. From Public Sources: We may gather information from publicly available profiles and websites.
We may combine information from these sources and use or disclose it for the purposes outlined below.
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We may collect the following types of Personal Information:
A. Identifiers: This includes your name, email address, physical address, phone number, business contact details, and device identifiers.
B. Records About You: We may gather financial information (including payroll account numbers), signatures, background check details (as permitted by law), and descriptions of your physical characteristics.
C. Protected Class and Demographic Information: This includes data such as your age (including birthdates) and gender.
D. Commercial Information: We may collect records of business transactions, salary and wage information, and payroll and benefits data.
E. Internet and Electronic Activity Information: This includes details related to your interactions with RWM networks, systems, devices, email, applications, and platforms, such as browsing history and search history.
F. Non-Precise Geolocation Data: This encompasses location information derived from your IP address.
G. Audio, Visual, or Sensory Information: We may collect photographs, security camera footage from public areas of RWM's facilities, and recordings of calls and video conferences.
H. Professional or Employment-Related Information: This includes job title, organization, professional licenses, credentials, specialties, affiliations, experience, references, performance evaluations, disciplinary records, resumes, interview notes, human resource records, payroll data, board appointments, and other professional details.
I. Education Information: We may collect information related to your educational background.
J. Inferences: We may draw inferences about your preferences and behavior based on the information we collect.
K. Sensitive Personal Information: This includes Social Security numbers, driver’s license numbers, passport numbers, account login information, racial or ethnic origin (if voluntarily provided), content of mail and messages we monitor for compliance and security, health information, medical insurance details, and information regarding sexual orientation (if voluntarily provided).
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We may use Personal Information for the following purposes:
A. Employment Application Processes: This includes assessing your application, interview, and test results for suitability for the position applied for or other openings; communicating with you about job opportunities; conducting pre-employment verification and screening; offering you a job at our discretion; notifying you of opportunities (including from affiliated entities); and addressing any inquiries or feedback related to our recruitment and hiring decisions.
B. Human Resources Management: This encompasses administering payroll and benefits (including leave of absence and pensions), managing corporate travel and reimbursable expenses, overseeing development and training, monitoring absences, tracking timekeeping, conducting performance appraisals, handling disciplinary matters, administering termination processes, planning careers, facilitating relocations, assessing qualifications for specific roles, conducting diversity and inclusion surveys, performing background and reference checks, and managing complaint or hotline programs.
C. Internal Business Purposes: We may use your information to improve our recruitment and employment functions, enforce policies, generate management reports, manage assets (including office locations and emergency planning), oversee project management and auditing, maintain records of employment-related activities, manage budgets, administer IT systems, ensure IT security, analyze meeting data (including recording discussions and presentations), document corporate decision-making, and enhance meeting management and productivity.
D. Internal Research and Business Improvement: Your information may be used for research and to identify areas for business improvement.
E. Legal, Safety, and Security Reasons: This includes complying with legal and reporting requirements; investigating claims against the Company or its personnel; establishing or defending legal claims; ensuring safety (including managing health concerns); detecting and preventing security incidents; and protecting against fraudulent or illegal activities.
F. Corporate Transactions: We may use your information in the context of corporate transactions, such as if we are acquired by another entity or if we acquire another company.
G. Marketing and Promotional Purposes: We may promote RWM and our business through social media, public relations, branding efforts, events, and direct outreach to business customers. This may involve publicly sharing the names and work contact details of sales representatives or posting images of Personnel at RWM events.
We may also use anonymized, de-identified, or aggregated information for any legally permissible purpose.
4. How We Disclose Personal Information
The following information will be laid out as follows Categories of Personal Information We Collect “title” and then Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose and Categories of Third Parties to Whom Personal Information is Sold* or Shared “content”
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Example: Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose
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• Affiliates and subsidiaries
• Benefits services providers
• Professional consultants
• Vendors necessary to complete transactions you request
• Law enforcement, government agencies, and other recipients for legal, security, and safety purposes
• Other entities in connection with a corporate transaction
• Entities to which you have consented to the disclosure -
• Affiliates and subsidiaries
• Benefits services providers
• Professional consultants
• Vendors necessary to complete transactions you request
• Law enforcement, government agencies, and other recipients for legal, security, and safety purposes
• Other entities in connection with a corporate transaction
• Entities to which you have consented to the disclosure -
• Affiliates and subsidiaries
• Benefits services providers
• Professional consultants
• Vendors necessary to complete transactions you request
• Law enforcement, government agencies, and other recipients for legal, security, and safety purposes
• Other entities in connection with a corporate transaction
• Entities to which you have consented to the disclosure -
• Affiliates and subsidiaries
• Benefits services providers
• Professional consultants
• Vendors necessary to complete transactions you request
• Law enforcement, government agencies, and other recipients for legal, security, and safety purposes
• Other entities in connection with a corporate transaction
• Entities to which you have consented to the disclosure -
• Affiliates and subsidiaries
• Benefits services providers
• Professional consultants
• Vendors necessary to complete transactions you request
• Law enforcement, government agencies, and other recipients for legal, security, and safety purposes
• Other entities in connection with a corporate transaction
• Entities to which you have consented to the disclosure -
• Affiliates and subsidiaries
• Benefits services providers
• Professional consultants
• Vendors necessary to complete transactions you request
• Law enforcement, government agencies, and other recipients for legal, security, and safety purposes
• Other entities in connection with a corporate transaction
• Entities to which you have consented to the disclosure -
• Affiliates and subsidiaries
• Benefits services providers
• Professional consultants
• Vendors necessary to complete transactions you request
• Law enforcement, government agencies, and other recipients for legal, security, and safety purposes
• Other entities in connection with a corporate transaction
• Entities to which you have consented to the disclosure -
• Affiliates and subsidiaries
• Benefits services providers
• Professional consultants
• Vendors necessary to complete transactions you request
• Law enforcement, government agencies, and other recipients for legal, security, and safety purposes
• Other entities in connection with a corporate transaction
• Entities to which you have consented to the disclosure -
• Affiliates and subsidiaries
• Benefits services providers
• Professional consultants
• Vendors necessary to complete transactions you request
• Law enforcement, government agencies, and other recipients for legal, security, and safety purposes
• Other entities in connection with a corporate transaction
• Entities to which you have consented to the disclosure -
• Affiliates and subsidiaries
• Benefits services providers
• Professional consultants
• Vendors necessary to complete transactions you request
• Law enforcement, government agencies, and other recipients for legal, security, and safety purposes
• Other entities in connection with a corporate transaction
• Entities to which you have consented to the disclosure -
• Affiliates and subsidiaries
• Benefits services providers
• Professional consultants
• Vendors necessary to complete transactions you request
• Law enforcement, government agencies, and other recipients for legal, security, and safety purposes
• Other entities in connection with a corporate transaction
• Entities to which you have consented to the disclosure
The categories of recipients listed above refer to:
A. Affiliates and Subsidiaries: This includes parent companies, corporate affiliates, subsidiaries, business units, and other entities with shared ownership.
B. Benefits Service Providers: These are companies that offer health, wellness, insurance, and other financial or voluntary benefits.
C. Professional Consultants: This category encompasses HR operations consultants, accountants, benefit consultants, IT consultants, staffing consultants, career development and training specialists, testing companies, lawyers, accountants, and financial advisors.
D. Vendors: These are necessary service providers involved in completing transactions you request, such as shipping companies.
E. Law Enforcement and Government Agencies: This includes recipients we may share information with for legal, security, or safety purposes, such as complying with laws, enforcing agreements and policies, and protecting the safety, property, or rights of the Company, our customers, or third parties.
F. Entities Involved in Corporate Transactions: This pertains to parties involved when we acquire assets or when our assets are acquired by another entity, including in cases of bankruptcy or other corporate changes.
G. Entities with Your Consent: This refers to any parties to whom you have agreed to disclose your information.