Effective Date: January 1, 2021

The California Consumer Privacy Policy Act (the “CCPA”) obligates covered businesses to disclose to consumers (including employees and job applicants), at or before the point of collecting personally identifiable information (“PII”), the categories of PII to be collected and the purposes for which the categories of PII shall be used. We encourage you to read it carefully.

I. Introduction

This notice (“Notice”) describes the categories of personal information that Pellenc America, Inc. (“firm”, “we”, “us” and “our”) collects about California residents who apply or are recruited for a job with us or one of our affiliates (“candidates”), and the purposes for which we use that information.

For purposes of this Notice, “personal information” has the meaning given in the CCPA, but excludes information exempted from the CCPA’s scope.

If you have questions about this Notice, please contact us at privacy@pellencus.com.

II. Information we collect about candidates

a. Categories of Personal Information

In the course of the job application process, we may collect the following categories of PII for the purposes of evaluating you as a job applicant:

  • Contact information, such as home address, telephone number, and email address;
  • Information from job application materials or recruiters, such as your job application, resume or CV, cover letter, writing samples, references, work history, information for checking conflicts of interest (such as your work with specific clients and on specific matters), education transcripts, whether you are subject to prior employer obligations, and information that referrers provide about you;
  • Professional qualifications, such as licenses, permits, memberships, and certifications;
  • Information from the application process, such as any phone-screens, interviews, evaluations and outcomes of recruiting exercises;
  • Immigration status and other information that would allow us to verify your employment eligibility at the appropriate time in the recruiting process, as permitted by law;
  • Biographical information, such as name, gender, professional history, references, language proficiencies, education details, and information you make publicly available through job search or career networking sites. We collect your date of birth after an offer is made and as part of the background check process;
  • Job preferences, such as desired position and compensation, location preferences and willingness to relocate;
  • Employment history;
  • Background check information, such as information necessary to complete background, credit, drug/alcohol and/or other checks when permitted by law, and information received during these checks;
  • Information needed to understand and assess accommodation requests regarding potential disabilities or other health conditions. This discussion would occur only after an offer of employment is made and accepted;
  • Medical information if you meet with us in-person, such as your body temperature, health symptoms and other screening information in connection with the firm’s health and safety plans and protocols, including screening required to access the firm’s offices/facilities and other measures designed to prevent the transmission of COVID-19 or other infectious diseases; and
  • Other information you provide to us.

Providing personal information to us is voluntary.  However, if you do not provide sufficient information, we may be unable to consider your application or, if you are hired, your subsequent promotion, transfer or relocation.

In certain cases we may ask you for additional information for purposes of complying with applicable laws.  We may also inquire about criminal records. We will do so only where permitted by applicable law.

b. Sources of personal information

We collect personal information from you when you apply for a job and throughout the job application or recruitment process.  We may also collect your personal information from other sources and combine it with the personal information you provide us.  For example, we may collect your personal information from:

  • Job board websites you may use to apply for a job with us;
  • Prior employers that provide us with employment references;
  • Professional references that you authorize us to contact;
  • Pre-employment screening services, such as background check providers (where permitted by law);
  • Employment agencies and recruiters;
  • Your educational institutions;
  • Publicly-available sources, including your public social media profile or other publicly-available sources;
  • Online activity information that we and our service providers collect using server logs, “cookies” and similar technologies on the Careers Site.
  • Other firm personnel.
  • Recruiting or other events where we are a sponsor or participant.

III. How we use personal information about candidates

 

a. Purposes for which we use personal information

We may use the categories of personal information above for the following purposes:

  • Recruitment management.Managing recruitment generally, such as:
  • recruiting, interviewing and evaluating job candidates;
  • conducting background checks and other pre-employment screening (where permitted by law);
  • analyzing and improving our application and recruitment processes;
  • accommodating disabilities or health conditions;
  • communicating with you regarding your candidacy, opportunities with the firm or about the Careers Site and any changes to applicable terms or policies; and
  • other business operations.
  • Compliance, safety and fraud prevention, such as:
    • complying with or monitoring compliance with legal and other requirements, such as reporting and equal opportunities monitoring requirements, where applicable;
    • complying with internal policies and procedures;
    • complying with lawful requests and legal process, such as responding to subpoenas or requests from government authorities;
    • protecting our, your or others’ rights, safety and property, including by complying with applicable public health guidelines and requirements, including, without limitation, guidance from the Centers for Disease Control or other public health authorities relating to the prevention and control of COVID-19 or other infectious diseases;
    • investigating and deterring against fraudulent, harmful, unauthorized, unethical or illegal activity, or conduct in violation of our policies or procedures;
    • controlling access to and monitoring our physical premises (e.g., by requiring health screenings to access offices/facilities; and
    • sharing information with government authorities, law enforcement, courts or private parties where we have a good-faith belief it is necessary for the foregoing purposes.
  • Creating anonymous, aggregated or de-identified data that we use and share to analyze our application and recruitment activities, business and for other lawful business purposes.

b. Sharing personal information

We may share your personal information with other parties as necessary for the purposes described above. For example, we may share your personal information with:

  • Affiliates. Our affiliated entities, for purposes consistent with this Notice or to operate shared infrastructure, systems and technology.
  • Firm service providers. Companies that provide us with services that help us manage the recruiting process and operate our business, such as job boards, recruiters, interviewing and testing, pre-employment screening, interview travel booking and expense reimbursement (where applicable), relocation (where applicable), and recruitment analytics.
  • Government authorities, law enforcement and others. Government authorities, law enforcement, courts, and others as described in the compliance, safety and fraud prevention section above.
  • Business transfers.  Parties to transactions and potential transactions whereby we sell, transfer or otherwise share some or all of our business or assets, including your personal information, such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
  • Professional advisors. Lawyers, immigration advisors, and other outside professional advisors.
  • Clients and business partners.  Clients, other companies and individuals with whom the firm does business or is exploring a business relationship.