Notice at Collection for California Employees and Applicants (CCPA and CPRA)
On June 30, 2023, the Superior Court of California for the County of Sacramento issued an order staying enforcement of the CPPA's March 2023 CCPA Regulations until March 29, 2024 (see CPRA-Related Enforcement Start Date).
CCPA Notice at Collection for California Employees and Applicants
Effective Date; August 1, 2023
This privacy notice is for California residents who are employees, prospective employees, retired employees, or job applicants (“California Workforce Members” or “you”) of Reliance World Wide Corporation, Ltd. Or any of its affiliates or subsidiaries (hereinafter “RWC”, “we”, or “us”). As detailed further below, RWC collects and uses your personal information, including sensitive personal information, for purposes associated with human resources, employment, benefits administration, health and safety, and business-related purposes and to be in legal compliance. We are committed to properly handling the personal information collected or processed in connection with your employment relationship with us.
We will not sell the personal information, including any sensitive personal information, that we collect about our employees or applicants for the above purposes, nor do we share it with third parties for cross-context behavioral advertising. Information collected about California Workforce Members in their capacity as customers or consumers of RWC products or services is governed by our Privacy Policy and associated privacy notices.
| Personal Information Category | Retention Period | Business Purpose | Sold or Shared |
|---|---|---|---|
| Personal Identifiers, such as your full name, contact information, gender, date of birth, signature, Social Security number, driver's license or state identification numbers, and similar information for your dependents and beneficiaries. | As long as reasonably necessary for the business purpose described. | Recruit and process employment applications, including verifying eligibility for employment and conducting background and related checks Conduct employee onboarding Maintain and administer payroll and employee benefit plans, including enrollment and claims handling Maintain personnel records and complying with record retention requirements Provide employees with human resources management services and employee data maintenance and support services Communicate with employees and their emergency contacts and plan beneficiaries Comply with applicable state and federal labor, employment, tax benefits, workers' compensation, disability, equal employment opportunity, workplace safety, and related laws Prevent unauthorized access to or use of the Company property, including information systems, electronic devices, network, and data Ensure employee productivity and adherence to Company policies Conduct internal audits and investigate complaints, grievances, and suspected violations of Firm policy Respond to law enforcement requests and as required by applicable law or court order Exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents. |
Not Sold. May be shared with third-party service providers to fulfill the business purposes described. |
| California Customer Records (Cal. Civ. Code 1798.80(e)) employment and personal information, such as your name, signature, Social Security number, physical characteristics or description, photograph, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, current employment, employment history, membership in professional organizations, licenses and certifications, bank account number, credit card number, debit card number, or any other financial, medical or health insurance information]. | As long as reasonably necessary for the business purpose described. | Same purposes as for identifiers category | Not Sold. May be shared with third-party service providers to fulfill the business purposes described. |
| Protected classification characteristics under California or federal law, such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, reproductive health decisionmaking, military and veteran status, or genetic information (including familial genetic information).] | As long as reasonably necessary for the business purpose described. | Comply with federal and state equal employment opportunity laws Design, implement, and promote the Company's diversity and inclusion programs Perform workforce analytics, data analytics, and benchmarking Conduct internal audits, grievances, and suspected violations of Company policy Exercise or defend the legal rights of the Company and its employees[,/ and] [affiliates,] customers[, contractors, and agents] |
Not Sold. May be shared with third-party service providers to fulfill the business purposes described. |
| Commercial information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | As long as reasonably necessary for the business purpose described. | Respond to law enforcement requests and as required by applicable law or court order. | Not Sold. May be shared with third-party service providers to fulfill the business purposes described. |
| Biometric information, such as facial recognition, fingerprints, iris or retina scans, keystroke, or other physical patterns, and certain wellness metrics. | As long as reasonably necessary for the business purpose described. | Fingerprinting for a criminal background check after an initial offer of employment is made. Criminal background checks protect the company, mitigate risk, and avoid potential negligent hiring lawsuits Administer and design health wellness programs Exercise or defend the legal rights of the Company and its employees[,/ and] [affiliates,] customers[, contractors, and agents] |
Not Sold. May be shared with third-party service providers to fulfill the business purposes described. |
| Internet or other similar network activity information, including all activity on the Company's information systems (such as internet browsing history, search history, intranet activity, email communications, social media postings, stored documents and emails, usernames, and passwords) and all activity on communications systems (such as phone calls, call logs, voicemails, text messages, chat logs, app use, mobile browsing and search history, mobile email communications, and other information regarding an employee's use of company-issued devices). | As long as reasonably necessary for the business purpose described. | Facilitate the efficient and secure use of Company information systems Ensure compliance with Company information systems policies and procedures. Comply with applicable state and federal laws Prevent unauthorized access to, use, or disclosure or removal of the Company's property, records, data, and information Enhance employee productivity Conduct internal audits and investigate complaints, grievances, and suspected violations of Firm policy Exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents. |
Not Sold. May be shared with third-party service providers to fulfill the business purposes described. |
| Geolocation data, such as the time and physical location related to use of an internet website, application, or device, and GPS location data from mobile devices of employees who participate in our vehicle reimbursement program. GPS location data from employees using RWC-issued vehicles. | As long as reasonably necessary for the business purpose described. | Improve safety of employees, customers, and the public regarding use of the Company property and equipment Prevent unauthorized access, use, or loss of the Company property Improve efficiency, logistics, and supply chain management Ensure employee productivity and adherence to the Company's policies Conduct internal audits and investigate complaints, grievances, and suspected violations of the Company's policy [USE PURPOSES] |
Not Sold. May be shared with third-party service providers to fulfill the business purposes described. |
| Sensory [and surveillance] data, such as COVID-19 related temperature checks and call monitoring and video surveillance. | As long as reasonably necessary for the business purpose described. | Comply with applicable state and federal laws, including on workplace health and safety Prevent unauthorized access, use, or loss of the Company property Improve customer service Exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents. |
Not Sold. May be shared with third-party service providers to fulfill the business purposes described. |
| Professional or employment-related information, such as employment application information (work history, academic and professional qualifications, educational records, references, and interview notes, background check, drug testing results, work authorization, performance and disciplinary records, salary, bonus, commission, and other similar compensation data, benefit plan enrollment, participation, and claims information, leave of absence information including religious, military and family obligations, health data concerning employee and their family members. | As long as reasonably necessary for the business purpose described. | Comply with applicable state and federal laws, including on workplace health and safety Prevent unauthorized access, use, or loss of the Company property Improve customer service Exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents. Recruit and process employment applications, including verifying eligibility for employment, background checks, and onboarding Design and administer employee benefit plans and programs, including for leaves of absence. Maintain personnel records and comply with record retention requirements. Communicate with employees and their emergency contacts and plan beneficiaries. Comply with applicable state and federal labor, employment, tax, benefits, workers' compensation, disability, equal employment opportunity, workplace safety, and related laws. Prevent unauthorized access to or use of the Company's property, including its information systems, electronic devices, network, and data. Ensure employee productivity and adherence to the Company policies. Conduct internal audits and investigate complaints, grievances, and suspected violations of the Company policy. Evaluate and provide useful feedback about job performance, facilitate better working relationships, and for employee professional development Exercise or defend the legal rights of the Company and its employees[,/ and] [affiliates,] customers[, contractors, and agents] |
Not Sold. May be shared with third-party service providers to fulfill the business purposes described. |
| Non-public education information, such as education records, degrees and vocational certifications obtained, report cards, and transcripts. | As long as reasonably necessary for the business purpose described. | Evaluate an individual's appropriateness for hire, or promotion or transfer to a new position at the Company. | Not Sold. May be shared with third-party service providers to fulfill the business purposes described. |
| Inferences drawn from other personal information to create a profile or summary, for example, an individual's preferences, abilities, aptitudes, and characteristics. | As long as reasonably necessary for the business purpose described. | Engage in human capital analytics, including to identify correlations about individuals and job success, analyze data to improve retention and productivity, and analyze employee preferences to inform human resources policies and procedures Conduct applicant reference checks to assist in hiring decisions |
Not Sold. May be shared with third-party service providers to fulfill the business purposes described. |
Sensitive personal information is a subtype of personal information consisting of specific information categories. While we collect information that falls within the sensitive personal information categories listed in the table below, the CCPA does not treat this information as sensitive because we do not collect or use it to infer characteristics about a person.
| Sensitive Personal Information Category | Retention Period | [Business Purpose] | [Sold or Shared] |
|---|---|---|---|
| Government identifiers, such as your Social Security number, driver's license, state identification card, and passport and visa information, and immigration status and documentation. | As long as reasonably necessary for the business purpose described. | Recruit and process employment applications, including verify eligibility for employment and conducting background and related checks Process and administer payroll and employee benefit plans, including enrollment and claims handling Maintain personnel records and comply with record retention requirements Provide employees with human resources management services and employee data maintenance and support services Communicate with employees and their emergency contacts and plan beneficiaries Comply with applicable state and federal labor, employment, tax benefits, workers' compensation, disability, equal employment opportunity, workplace safety, and related laws Prevent unauthorized access to or use of the Company property, including information systems, electronic devices, network, and data Respond to law enforcement requests and as required by applicable law or court order |
Not Sold. May be shared with third-party service providers to fulfill the business purposes described. |
| Complete account access credentials, such as user names, account numbers, or card numbers combined with required access/security code or password. | As long as reasonably necessary for the business purpose described. | Recruit and process employment applications, including verify eligibility for employment and conducting background and related checks Process and administer payroll and employee benefit plans, including enrollment and claims handling Maintain personnel records and comply with record retention requirements Provide employees with human resources management services and employee data maintenance and support services Communicate with employees and their emergency contacts and plan beneficiaries Comply with applicable state and federal labor, employment, tax benefits, workers' compensation, disability, equal employment opportunity, workplace safety, and related laws Prevent unauthorized access to or use of the Company property, including information systems, electronic devices, network, and data Respond to law enforcement requests and as required by applicable law or court order Recruit and process employment applications, including verify eligibility for employment and conducting background and related checks. Provide employees with human resources management services and employee data maintenance and support services Prevent unauthorized access to or use of the Company information systems, electronic devices, network, and data [USE PURPOSES] |
Not Sold. May be shared with third-party service providers to fulfill the business purposes described. |
| Precise geolocation, such as physical access to a Company office location, or the location of a delivery, sales, or other employee in the field. | As long as reasonably necessary for the business purpose described. | Improve safety of employees, customers, and the public regarding use of the Company property and equipment Prevent unauthorized access, use, or loss of the Company property Improve efficiency, logistics, and supply chain management Ensure employee productivity and adherence to the Company's policies Conduct internal audits and investigate complaints, grievances, and suspected violations of the Company's policy Exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents |
Not Sold. May be shared with third-party service providers to fulfill the business purposes described. |
| Racial or ethnic origin. | As long as reasonably necessary for the business purpose described. | Comply with federal and state equal employment opportunity laws Design, implement, and promote the Company's diversity and inclusion programs Perform workforce analytics, data analytics, and benchmarking Conduct internal audits and investigate complaints, grievances, and suspected violations of Company policy |
Not Sold. May be shared with third-party service providers to fulfill the business purposes described. |
| Religious or philosophical beliefs. | As long as reasonably necessary for the business purpose described. | Review and process religious reasonable accommodation requests Exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents |
Not Sold. May be shared with third-party service providers to fulfill the business purposes described. |
| Union membership. | As long as reasonably necessary for the business purpose described. | Implement appropriate policies and procedures Deduct union dues from paychecks |
Not Sold. May be shared with third-party service providers to fulfill the business purposes described. |
| Mail, email, or text messages contents not directed to the Company. | As long as reasonably necessary for the business purpose described. | Conduct internal audits and investigate complaints, grievances, and suspected violations of the Company policy Exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents |
Not Sold. May be shared with third-party service providers to fulfill the business purposes described. |
| Genetic data. | As long as reasonably necessary for the business purpose described. | Investigate and process workers' compensation claim Process health insurance claims Conduct and process employment testing |
Not Sold. May be shared with third-party service providers to fulfill the business purposes described. |
| Unique identifying biometric information. | As long as reasonably necessary for the business purpose described. | Fingerprinting for a criminal background check after an initial offer of employment is made. Criminal background checks protect the company, mitigate risk, and avoid potential negligent hiring lawsuits Ensure accurate time records Exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents |
Not Sold. May be shared with third-party service providers to fulfill the business purposes described. |
| Health information, including job restrictions and workplace illness and injury information. | As long as reasonably necessary for the business purpose described. | Investigate and process workers' compensation claims Process health insurance claims Conduct and process employment testing Ensure equal access to retirement programs and fertility planning by same-sex spouses Ensure equal family leave policies and insurance for transgender surgeries |
Not Sold. May be shared with third-party service providers to fulfill the business purposes described. |
| Sex life or sexual orientation information. | As long as reasonably necessary for the business purpose described. | Process health insurance claims Ensure equal access to retirement programs and fertility planning by same-sex spouses Ensure equal family leave policies and insurance for transgender surgeries |
Not Sold. May be shared with third-party service providers to fulfill the business purposes described. |
Contact Us
If you have any questions about this Notice or need to access this Notice in an alternative format due to having a disability, please contact us as set out below:
Mail:
RWC Privacy
2300 Defoor Hills Rd. NW
Atlanta, GA 3 0318
United States
Phone:
Email:
[email protected]
Effective date: August 1, 2023