California Consumer Privacy Act Notice for Current or Former Employees, Board Members, Contractors, Interns, Externs, and Job Applicants
Last Reviewed and/or Updated: February 1, 2023
Recology Inc. and its affiliates (“Recology,” “we,” “us” or “our”) are providing the following details regarding the Personal Information that we collect and use about California residents in the context of their current, former or potential role as our employees, board members, contractors, interns, externs, or job applicants (collectively, “covered individuals“). We may not collect each category of Personal Information identified below about all covered individuals. We supply this information consistent with the California Consumer Privacy Act of 2018, as amended by the Consumer Privacy Rights Act of 2020 (collectively, the “CCPA”).
Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular California resident or household. If you are an employee or director this Notice also applies to the beneficiaries of your employment benefits, such as the individuals who are on your health plan and the beneficiaries of your retirement accounts, as well as your emergency contacts. It is your responsibility to inform any such individuals about this Notice and ensure that you have the right to provide their Personal Information to us.
Categories of Personal Information
We collect the following categories of Personal Information:
- Identifiers, such as name, contact information, online identifiers, IP address, Social Security numbers, and other government-issued ID numbers;
- Personal information, as defined in the California customer records law, such as name, contact information, education information, employment history, financial information, and medical and medical insurance information;
- Characteristics of protected classifications under California or federal law, such as sex, age, race, religion, national origin, disability, medical conditions and information, citizenship, immigration status, request for leaves of absence, and marital status;
- Commercial information, such as transaction information and purchase history, including travel expenses and information about corporate credit card purchases;
- Biometric information, such as fingerprints;
- Internet or network activity information accessed on company issued devices, such as browsing history and interactions with our and other websites and systems;
- Geolocation data, such as device location and IP location in connection with our business activities;
- Audio, electronic, visual, and similar information, such as photographs or audio or video recordings created in connection with our business activities;
- Professional or employment-related information, such as work history, prior employer, information relating to references, details of qualifications, safety record, agility, skills and experience, human resources data, and data necessary for benefits and related administration services;
- Education information subject to the federal Family Educational Rights and Privacy Act;
- Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences, behavior, or characteristics; and
- Sensitive Personal Information, including Personal Information that reveals an individual’s Social Security, driver’s license, state identification card, or passport number; 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; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, citizenship, immigration status, or union membership; the contents of mail, email, and text messages unless Recology is the intended recipient of the communication; genetic data; the processing of biometric information for the purpose of uniquely identifying an individual; Personal Information collected and analyzed concerning an individual’s health; Personal Information collected and analyzed concerning an individual’s sex life (in certain limited circumstances) or sexual orientation].
Sources of Personal Information
We collect Personal Information directly from you and from our affiliates, your colleagues and managers, references you provide, recruiting firms, prior employers or schools, clients, private and government screening and background check providers, results of screening or random substance testing, providers of employee benefits, social networks, publicly available databases, court orders, government inquiries or communications, and cooperative databases.
Purposes for the Collection, Use, and Disclosure of Personal Information
We collect, use, and disclose Personal Information for the purposes of operating, managing, and maintaining our business, managing our recruitment process, workforce management and other employment purposes, and accomplishing our business purposes and objectives, including, for example, using Personal Information to:
- Manage workforce activities and personnel generally, including for recruitment, safety, performance management, career development, payments administration, employee training, leaves and promotions;
- Receive and process job applications and manage the applicant selection process, including contacting you about future work opportunities;
- Conduct reference, safety, health, fitness, and background checks, consistent with applicable law;
- Manage wages and other awards, such as stock options, stock grants and bonuses, and provide healthcare, pensions, savings plans and other benefits;
- Maintain and secure our facilities, equipment, systems, and infrastructure;
- Undertake quality and safety assurance measures, protect the health and safety of our workforce and others, and conduct risk and security control and monitoring;
- Conduct research, analytics, and data analysis to assist in planning succession and to ensure business continuity, as well as to design employee retention programs and diversity initiatives;
- Perform identity verification, accounting, audit, and other internal functions, such as internal investigations;
- Operate and manage IT and communications systems and facilities, allocate company assets and human resources, and undertake strategic planning and project management; and
- Comply with law, legal process, internal policies and other requirements such as income tax deductions, record-keeping and reporting obligations, and exercise and defend legal claims.
Disclosure of Personal Information
In the preceding 12 months, we disclosed for our operational business purposes the following categories of Personal Information to the following categories of third parties:
| Categories of Disclosed Information | Disclosed to Which Categories of Third Parties for Operational Business Purposes |
|---|---|
| Identifiers | Our affiliated entities; trusted third-party service providers and other third parties in connection with your temporary or permanent employment, including recruitment, preemployment screening, hiring, retention, insurance and other employee benefits, payroll, stock grants, retirement benefits, security, audits, internal and external communications, investigation, risk management, and legal claims. |
| Personal information, as defined in the California customer records law | Our affiliated entities; trusted third-party service providers and other third parties in connection with your temporary or permanent employment, including recruitment, preemployment screening, hiring, retention, insurance and other employee benefits, payroll, stock grants, retirement benefits, security, audits, internal and external communications, investigation, risk management, and legal claims. |
| Characteristics of protected classifications under California or federal law | Our affiliated entities; trusted third-party service providers and other third parties in connection with your temporary or permanent employment, including recruitment, preemployment screening, hiring, retention, insurance and other employee benefits, payroll, stock grants, retirement benefits, security, audits, internal and external communications, investigation, risk management, and legal claims. |
| Commercial information | Our affiliated entities; trusted third-party service providers and other third parties in connection with your temporary or permanent employment, including recruitment, preemployment screening, hiring, retention, insurance and other employee benefits, payroll, stock grants, retirement benefits, security, audits, internal and external communications, investigation, risk management, and legal claims. |
| Biometric information | Our affiliated entities; trusted third-party service providers and other third parties in connection with your temporary or permanent employment, including recruitment, preemployment screening, hiring, retention, insurance and other employee benefits, payroll, stock grants, retirement benefits, security, audits, internal and external communications, investigation, risk management, and legal claims. |
| Internet or network activity information | Our affiliated entities; trusted third-party service providers and other third parties in connection with your temporary or permanent employment, including recruitment, preemployment screening, hiring, retention, insurance and other employee benefits, payroll, stock grants, retirement benefits, security, audits, internal and external communications, investigation, risk management, and legal claims. |
| Geolocation data | Our affiliated entities; trusted third-party service providers and other third parties in connection with your temporary or permanent employment, including recruitment, preemployment screening, hiring, retention, insurance and other employee benefits, payroll, stock grants, retirement benefits, security, audits, internal and external communications, investigation, risk management, and legal claims. |
| Audio, electronic, visual, and similar information | Our affiliated entities; trusted third-party service providers and other third parties in connection with your temporary or permanent employment, including recruitment, preemployment screening, hiring, retention, insurance and other employee benefits, payroll, stock grants, retirement benefits, security, audits, internal and external communications, investigation, risk management, and legal claims. |
| Professional or employment-related information | Our affiliated entities; trusted third-party service providers and other third parties in connection with your temporary or permanent employment, including recruitment, preemployment screening, hiring, retention, insurance and other employee benefits, payroll, stock grants, retirement benefits, security, audits, internal and external communications, investigation, risk management, and legal claims. |
| Education information | Our affiliated entities; trusted third-party service providers and other third parties in connection with your temporary or permanent employment, including recruitment, preemployment screening, hiring, retention, insurance and other employee benefits, payroll, stock grants, retirement benefits, security, audits, internal and external communications, investigation, risk management, and legal claims. |
| Inferences | Our affiliated entities; trusted third-party service providers and other third parties in connection with your temporary or permanent employment, including recruitment, preemployment screening, hiring, retention, insurance and other employee benefits, payroll, stock grants, retirement benefits, security, audits, internal and external communications, investigation, risk management, and legal claims. |
| Sensitive Personal Information | Our affiliated entities; trusted third-party service providers and other third parties in connection with your temporary or permanent employment, including recruitment, preemployment screening, hiring, retention, insurance and other employee benefits, payroll, stock grants, retirement benefits, security, audits, internal and external communications, investigation, risk management, and legal claims. |
We may also disclose the above categories of Personal Information to a third party in the context of any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
We do not sell your Personal Information, including your Sensitive Personal Information, and we do not “share” or otherwise process your Personal Information, including your Sensitive Personal Information, for purposes of cross-context behavioral advertising, as defined under the CCPA. We have not engaged in such activities in the 12 months preceding the date this Notice was last updated. Without limiting the foregoing, we do not sell or share the Personal Information, including the Sensitive Personal Information, of minors under 16 years of age.
Purposes for the Collection, Use, and Disclosure of Sensitive Personal Information
We may use and disclose Sensitive Personal Information for purposes of performing services for our business, providing services as requested by you, and ensuring the security and integrity of our business, infrastructure, and the individuals with whom we interact. This includes, without limitation, establishing and maintaining your working relationship with us, ensuring the diversity of our workforce, complying with legal obligations, managing payroll and corporate credit card use, administering and providing benefits, and securing the access to, and use of, our facilities, equipment, systems, networks, applications, and infrastructure.
Retention Period
We retain Personal Information, including Sensitive Personal Information, for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include:
- The duration of your employment or contract with us;
- The duration of the job application process, whether your job application is approved, and whether you want to be notified of future job opportunities;
- The length of time we have an ongoing relationship with you or your dependents/beneficiaries and the length of time thereafter during which we may have a legitimate need to reference your Personal Information to address issues that may arise;
- Whether there is a legal obligation to which we are subject, for example, certain laws may require us to keep your application or employment records for a certain period of time; and
- Whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation, or regulatory investigations.
Individual Rights and Requests
If you are a covered individual, you may make the following requests:
- “Request to Know”: You may request that we disclose to you the following information:
- The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
- The specific pieces of Personal Information we collected about you;
- The business or commercial purpose for collecting (if applicable) Personal Information about you; and
- The categories of Personal Information about you that we disclosed, and the categories of third parties to whom we disclosed such Personal Information (if applicable).
- “Request to Delete”: You may request that we delete Personal Information we collected from you.
- “Request to Correct”: You may request that we correct inaccuracies in your Personal Information.
To make a Request to Know, Delete, or Correct, please contact us as directed below by completing our request form, calling us at 800-652-1275, or emailing us at privacy@recology.com. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request by providing additional information by completing our form or by other means available to you. We may need to request additional Personal Information from you, such as email address, mailing address, Recology employee number/name, service levels, or prior correspondence, in order to verify your identity and protect against fraudulent requests. You may make a request on behalf of a dependent or beneficiary who is a child under 13 years old if you are the child’s parent or legal guardian. If you make a Request to Delete, we may ask you to confirm your request before we delete your Personal Information. You have the right to be free from unlawful retaliation for exercising your rights under the CCPA.
Authorized Agents
If an agent would like to make a request on your behalf as permitted by applicable law, the agent may use the submission methods noted above. As part of our verification process, we may request that the agent provide proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Individual Rights and Requests” or confirm that you provided the agent permission to submit the request.
Changes to this CCPA Notice
We may change or update this CCPA Notice from time to time. When we do, we will post the revised CCPA Notice on this page with a new “Last Updated” date.
Contact Us
Please contact us by email at privacy@recology.com, by calling (800) 652.1275, or by reaching out to your local Human Resources Partners, if you have any questions regarding this CCPA Notice.