CCPA Recruitment Privacy Notice
Last Updated: September 25th, 2020
The California Consumer Privacy Act of 2018, as amended (“CCPA”), imposes specific obligations on businesses processing personal information of California residents.
Pursuant to the CCPA, GlobalLogic group, including GlobalLogic Inc., Method Inc., Skookum Business Services Inc. and Skookum Inc. (together “GlobalLogic”, “we” or “us”) is required to provide its employees and job applicants, who are California residents (“California Employees”) a notice, used at or before the point of collection of such personal information, that identifies the categories of personal information that may be collected and why GlobalLogic collects such information.
This document (“Notice”) is intended to provide California Employees with the CCPA required notice.
This Notice will be reviewed once every 12 months to reflect changes in our business, legal or regulatory obligations, so please check this Notice periodically for changes.
Apart from what is set forth in this Notice, GlobalLogic will not collect additional categories of your personal information or use your already-collected personal information for additional purposes without providing you with a notice of our intent to do so. If we seek to use your previously collected personal information for a purpose materially different than what was disclosed to you at the point of collection, we will seek explicit consent from you to use the personal information for the new purpose.
Any changes to this Notice will be effective from the date they are communicated to you. If we make any material changes to this Notice, we will notify you by email.
2.1 “Personal information” has the meaning as defined in the CCPA, and includes information that is collected by GlobalLogic about you in the course employment for 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.
2.2 “Process”, “processed” or “processing” means any operation or set of operations which is performed on personal information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal information.
2.3 “Employees”, “employee” or “you” means an identified or identifiable natural person who is a California resident and who is acting as a GlobalLogic job applicant, employee, or contractor. In this context “job applicant” refers to any person who has submitted his or her candidacy with GlobalLogic; “employee” refers to any person who is employed at GlobalLogic as a full-or part-time employee or temporary worker, and “contractor” means a natural person who provides any service to a business pursuant to a written contract. “Employee” refers also to a natural person’s former role as a job applicant, employee, or contractor, staring from the effective date of the CCPA on January 1, 2020.
3. Personal Information We Collect About You
Listed below are the categories of personal information that GlobalLogic may process about California Employees:
3.1 Identifiers, including real name, aliases, postal addresses, unique personal identifiers, email address, account names, government issued identification, including but not limited to social security or taxpayer identification, driver’s license or state ID, passport, or other similar identifiers.
3.1.1 In this context, a “unique personal identifier” means a persistent identifier that can be used to recognize an employee, or a device that is linked to an employee, over time and across different services, including, but not limited to, a login, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers.
3.2 Characteristics of Protected Classifications Under California or Federal Law, including the following: national origin, sex/gender (includes pregnancy, childbirth, breastfeeding and/or related medical conditions), marital status, disability (mental and physical), military or veteran status, request for family care leave, request for leave for an employee’s health or family member condition, request for pregnancy disability leave, and age.
3.3 Biometric Information, including imagery of your fingerprint, face, and voice recordings.
3.4 Internet or Other Electronic Network Activity Information, including browsing history, search history and information regarding an employee’s interaction with an internet or intranet website, application or advertisement.
3.5 Professional or Employment-related Information, including job related data, maintained as part of the employment relationship that is present in: a job application or resume; an employment contract; a contractor agreement; a background check; a performance review; a disciplinary record; photos; information from company devices or vehicles; payroll and benefits related data; technical skills and other qualification exams; internal and external contact information; or information captured from video, audio, systems, or other forms of monitoring or surveillance. We may also collect and process immigration applications for employees, which may include information about employees’ families, and employment benefits information, which may include information in relation to employees’ dependents or beneficiaries that receive access to certain programs through the employee’s work with GlobalLogic.
3.6 Education Information, including information about an employee’s educational background, such as education records, report cards, and transcripts that are not publicly available.
3.7 Inferences, including any information drawn from any of the personal information categories referenced above to create a profile about an employee reflecting the employee’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
4. Purposes for Collecting Your Personal Information
GlobalLogic collects the personal information identified in Section 3 above for the reasons listed below.
4.1 To Recruit Employees, including to conduct employment- and education-related background screening and checks, and to ensure technical capabilities.
4.2 To Administer Benefits, such as medical, pension and dental benefits, including recording and processing eligibility of dependents, absence and leave monitoring, insurance and accident management and provision of online total reward information and statements.
4.3 To Pay and Reimburse for Expenses, including salary administration, payroll management, payment of expenses, to administer other compensation related payments, including assigning amounts of bonus payments to individuals, administration of departmental bonus pools and administration of stock option payments.
4.4 To Conduct Performance-Related Reviews, including performance appraisals, career planning, skills monitoring, job moves, promotions and staff re-structuring.
4.5 To Monitor Work-Related Licenses and Credentials, including ensuring compliance, training, examination and other requirements are met with applicable regulatory bodies or internal GlobalLogic compliance and training standards.
4.6 To Provide Our Employees with Human Resources Management Services, including providing employee data maintenance and support services, administration of separation of employment, approvals and authorization procedures, administration and handling of employee claims, and travel administration.
4.7 To Administer International Assignments, including relocation services, documenting assignment terms and conditions, obtaining relevant immigration documents, initiating vendor services, fulfilling home/host country tax administration and filing obligations, addressing health requirements and populating the International Mobility global system.
4.8 To Maintain Your Contact Information, including sharing your details with relevant entities within the GlobalLogic group of companies (for example personal, other employment and transferring roles).
4.9 To Assist You in Case of Emergency, including maintenance of contact details for you, and your dependents in case of personal or business emergency.
4.10 To Facilitate or Monitor Eligibility to Work in the U.S., which may include obtaining visas, monitoring or ensuring compliance of employees’ ability to work in the U.S.
4.11 To Meet Health Accommodations, identifying appropriate health or disability-related accommodations, operation of sickness policies and procedures.
4.12 To Facilitate Better Working Environment, which includes conducting staff surveys, providing senior management information about other employees, and conducting training.
4.13 To Ensure a Safe and Efficient Working Environment, which includes GlobalLogic actions relating to disciplinary actions, union grievances, code of conduct processes and investigations.
4.14 To Maintain Security on GlobalLogic Websites and Internet Connected Assets, which includes hosting and maintenance of computer systems and infrastructure; management of GlobalLogic’s software and hardware computer assets; systems testing, such as development of new systems and end-user testing of computer systems; training; and monitoring email and Internet access.
4.15 To Comply with Applicable Law or Regulatory Requirements, such as legal (state and federal) and internal GlobalLogic reporting obligations, including headcount, management information, demographic and Health, Safety, Security and Environmental reporting.
5. Further Information
If you have any questions about this statement, please contact GlobalLogic Privacy Team at firstname.lastname@example.org.