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Employee Data Privacy Notice
California Consumer Privacy Notice to California Employees and Job Applicants
This California Employee Privacy Notice (the “California Employee Privacy Notice” or “Notice”) supplements the Electro Rent Corporation Privacy Notice and applies to the personal information collected by Electro Rent Corporation (“Electro Rent” or the “Company”) of residents of California that are employees, interns, contractors, or volunteers of Electro Rent, engaged to provide services to Electro Rent, or that apply for a job with Electro Rent. This California Employee Privacy Notice also applies to information provided to us about employees’ relatives or others that is used for emergency contact or benefits administration purposes.
Please read this Notice to learn how we collect and process your personal information. Under the California Consumer Privacy Act of 2018, Cal. Civ. Code § 1798.100 et seq. and its implementing regulations (the “CCPA”), as modified by the California Privacy Rights Act (the “CPRA”), you have the right to know and understand the categories of personal information we collect about you, and the purposes for which we use such personal information. Certain terms used in this California Privacy Notice have the meaning given to them in the CCPA or CPRA, and their implementing regulations. This California Employee Privacy Notice only applies to employees, interns, contractors, volunteers and job applicants who are residents of the State of California. The Company does not sell or otherwise disclose this personal information for monetary or other consideration to any third parties.
Employee CPRA Rights
Under California law our California employees have the following rights:
- The right to receive disclosure about our Information Collection Practices. This disclosure is provided below.
- The right to receive disclosure about our Information Disclosure Practices. This disclosure is provided below.
- The right to tell us not to sell your personal information. Electro Rent does not sell your personal information.
- The right to tell us not to share your personal information for behavioral or cross-context marketing purposes. Electro Rent does not share your personal information for this purpose.
- The right to tell us not to process your Sensitive Personal Information for purposes other than the purposes for which it was originally collected. Electro Rent only processes Sensitive Personal Information for the purpose for which it was originally collected.
- The right to request that we correct information that is incorrect. Please see below for how to exercise this right.
- The right to request a copy of personal information we collected about you during the past 12 months or, at your option, since January 1, 2022, subject to certain exceptions. Please see below for how to exercise this right.
- The right to request that we delete Personal Information subject to certain exceptions. Please see below for how to exercise this right.
Categories of Personal Information We Collect
Electro Rent collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device (“personal information”). We collect and use personal information for human resources, employment, benefits administration, health and safety, and business-related purposes and to be in legal compliance. Below are the categories of personal information we collect about employees:
Category | Examples | Collected |
A. Identifiers | A real name, IP address, email address, or other similar identifiers. | YES |
B. Personal Information Categories listed in the California Customer Records Statute (Cal. Civ. Code §1798.80(e)) | A name, signature, Social Security Number, address, telephone number, passport number, driver’s license number, insurance policy number, education, employment history, bank account number, credit card number, financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | YES |
C. Protected classification characteristics under California or Federal law. | Age, race, ancestry, national origin, citizenship, religion, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, pregnancy, childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information. | YES |
D. Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies as related to Electro Rent Products. | YES |
E. Biometric Information | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | YES |
F. Internet or similar network activity | Browsing history, search history, information on interaction with a website, application, or advertisement. | YES |
G. Geolocation Data | Physical location or movements. | YES |
H. Sensory Data | Audio, electronic, visual, thermal, olfactory, or similar information. | YES |
I. Professional or employment-related information. | Current or past job history or performance evaluations. | YES |
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g; 34 CFR Part 99). | Education records directly related to a student maintained by an educational intuition or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | YES |
Sensitive Personal Information (as defined in the CPRA) | Social Security or other state identification number, a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, consumer’s geolocation, consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership, the contents of a consumer’s mail, email, or text messages, unless the business is the intended recipient of the communication, and consumer’s genetic data. | YES |
We also may collect personal information included in job interview notes, responses to screening questions, assessment results and any other information you provide in connection with the recruitment process.
Information Collection Practices: How We Collect and Use Personal Information of Employees
We collect personal information you voluntarily provide to us during the application process or when you otherwise contact us. We may also automatically collect certain information, such as IP addresses and device identifiers.
We may combine personal information you voluntarily provide to us with information we collect from other sources, such as:
- Recruiters;
- Prior employers and professional references;
- Educational institutions;
- Pre-employment screening and background check services;
- Credentialing and licensing organizations;
- Publicly available sources, such as public social media profiles on LinkedIn, Twitter or Facebook; and
- Other sources as directed by you
We use the categories of personal information above for the following business purposes:
- Recruitment of Employees and Processing and Managing Job Applications: We use your personal information to process your job application, create an applicant profile, evaluate your qualifications, schedule and conduct interviews and communicate with you.
- Conducting Pre-Employment Screening and Background Checks: In accordance with applicable law, we use your personal information to conduct employment screening and background checks.
- Compensation and Expense Management: We use your personal information to conduct payroll processing, salary administration, expense reimbursement, manage the Company’s corporate credit card program and other compensation purposes such as determining bonuses, equity and other forms of employee compensation.
- Benefits Administration: We use your personal information we collect to administer benefits we provide, such as medical, dental, vision, disability insurance, retirement benefits and other employee benefit programs.
- General Human Resources Management: We use your personal information we collect to provide general HR management services, including managing employee on-boarding, termination and separation, travel administration and return-to-work screening (including any medical screening as required or permitted by applicable law).
- Training and Professional Development: We use your personal information to provide employment-related training, assisting with professional licensing and development.
- Internal Employment Purposes: We use your personal information to conduct internal investigations, conduct surveys, resolve disputes, prevent or detect fraud or security incidents, conduct employee performance reviews, enforce our policies and code of conduct, protect the rights and safety of employees or others and manage whistleblower programs.
- Compliance with Legal Requirements and Enforcement of Our Legal Rights: We use your personal information to comply with applicable laws, regulations and legal processes (such as responding to subpoenas or court orders), and to respond to legal claims, resolve disputes, enforce our legal rights contained in employment or other contracts and comply with legal or regulatory recordkeeping requirements.
Disclosure of Personal Information
We may share your personal information for the business purposes described in this California Employee Privacy Notice with the following parties:
- Affiliates and Subsidiaries: We may share your personal information with our affiliates and subsidiaries.
- Service Providers: We may share your personal information with service providers, such as recruiters, pre-employment screening services, third-party benefits administrators, payroll processors, background check providers and others.
- Governmental Authorities: As required by law or legal process, we may share your personal information with federal or state regulatory agencies, law enforcement, courts and other governmental authorities.
- Professional Advisors: We may share your personal information with our professional advisors, such as law firms and auditors.
- Parties Involved with Business Transfers: We may share your personal information to third parties in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).
In accordance with our policies and procedures, we will not discriminate or retaliate against you if you choose to exercise any of your rights under the CCPA or CPRA.
Processing Employees Sensitive Personal Information
We do NOT process Sensitive Personal Information for purposes other than the purpose for which it was originally collected.
Data Retention
We will keep personal information no longer than necessary to fulfil the purposes described in this California Employee Privacy Notice. Under our record retention policy, we are required to destroy personal information after we no longer need it according to specific retention periods. However, we may need to hold personal information beyond these retention periods due to regulatory requirements or in response to a regulatory audit, investigation, or other legal matter.
How to request correction of your information
If you believe that information that we hold about you is incorrect or needs to be updated, please contact privacy@electrorent.com. You can make this request at any time. We will acknowledge receipt of your request within 10 business days, and we will correct your information promptly (and at least within 45 days) after verifying your request.
How to request a copy of your information
If you would like to receive a copy of the information collected about you during the past 12 months (or at your option, since January 1, 2022) please contact privacy@electrorent.com. Certain information will not be released to you because of legal restrictions or because the information is used for security purposes. You may make this request up to twice in any calendar year. We will acknowledge receipt of your request within 10 business days and provide a copy of your information in an easily readable format within 45 days. If we need an additional 45 days to compile your information we will let you know.
How to request deletion of your information
If you would like for us to delete information that we are permitted by law to delete, please contact privacy@electrorent.com. We are not permitted to delete information that we need in order to operate our business, administer our employees, protect our legal obligations and rights, or to provide security for our employees, our systems and our company. You may make this request up to twice in any calendar year. We will acknowledge receipt of your request within 10 business days and honor your request within 45 days. If we need an additional 45 days to respond we will let you know.
Non-Discrimination
We will not discriminate against you as a result of your exercise of any of these rights.
How to Contact Us
If you have any other questions or concerns regarding this Notice or the collection of your personal information, please contact: privacy@electrorent.com.
Changes to This Notice
We reserve the right to amend this Notice at our discretion at any time. When we make changes to this Notice, we will post the updated notice on our website and update the Notice’s effective date.
Effective Date: January 1, 2023