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This California Job Applicant Privacy Notice (this “Applicant Notice”) explains how Cadent LLC and its subsidiaries and affiliates (collectively, “Cadent, “we,” “us,” or “our”) processes personal information about our California-based job applicants under the California Consumer Privacy Act (CCPA) (collectively, “applicants,” “you,” or “your”). For purposes of this Applicant Notice, “personal information” has the meaning given to it in the CCPA.
In connection with an individual’s role as a job applicant, in the last 12 months, we have collected the following categories of personal information along with representative examples:
|Categories of Personal
Records (Cal. Civ. Code §
related information (for
example, resumes, references,
|Inferences drawn from
Certain “sensitive” information may be revealed by virtue of submission of your job applicant materials or correspondence with our team (e.g., information contained within a resume/CV), such as race/ethnic origin, religious/philosophical beliefs, or data concerning health. Pursuant to the CCPA, we will process such data only for purposes that do not require an opt-out under the CCPA (i.e., the “right to limit”) or otherwise without the purpose of inferring characteristics about you.
We collect personal information directly from you when you apply for a job and throughout the job application or recruitment process. We also collect your personal information from other sources and may use it in conjunction with the personal information you provide us. For example, we may collect your personal information from:
We may use the categories of personal information above for the following purposes:
We may share your personal information with other parties as necessary for the purposes described above. For example, we may disclose your personal information with:
We retain the categories of personal information listed above as reasonably necessary to fulfill the purposes outlined in this Applicant Notice, unless a longer retention period is required or permitted by law. In many situations, we must retain all, or a portion, of your personal information to comply with legal obligations, resolve disputes, enforce our agreements, protect against fraudulent, deceptive, illegal, or otherwise harmful activity, or for another one of our business purposes.
Relatedly, note that we may retain application information for unsuccessful applicants beyond consideration of the immediate position for which the application is submitted as a reference in case future positions become available and are of interest. Application information for successful applicants may become part of the applicant’s employment file and is treated accordingly.
As a California resident, you may be able to exercise the following rights, subject to certain limitations (e.g., where exercise of the rights involves disproportionate efforts, reveals confidential company information, adversely affects the rights and freedoms of other persons, is related to the exercise or defense of legal claims or similar potential or actual dispute, or as otherwise explained in further guidance from California regulators):
|The Right to Know
Subject to certain exceptions (such as where such requests involve disproportionate effort or where a request was made more than twice in a 12-month period), the right to request that we disclose information about our collection and use of your personal information, including:
|The Right to Correction
|The right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data
|The Right to Deletion
|The right to have us delete the personal data we maintain about you, subject to certain exceptions.
Further, as stated above, we do not process your “sensitive” personal information for any purpose that requires a corresponding opt-out right under the CCPA (i.e., the “right to limit”).
To submit a request to exercise one of the privacy rights identified above, please:
Email [email protected] and specifying (i) what type of request you are making (I.e., access, correction, or deletion) and (ii) that you are making such request pursuant to this Job Applicant Privacy Notice specifically.
Before processing your request, we will need to verify your identity and confirm you are a resident of the State of California. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. We may at times need to request additional personal information from you, taking into consideration our relationship with you and the sensitivity of your request.
In certain circumstances, we may decline a privacy rights request, particularly where you are not a resident of the State of California or where we are unable to verify your identity.
Pursuant to the CCPA, you have the right to not receive discriminatory adverse treatment for exercising any of
your CCPA rights.
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above, where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. We may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.
Any change to this Applicant Notice shall be effective once the modified Applicant Notice is made available on this website, and we will update the “Effective Date” accordingly.
If you have any questions or requests in connection with this Applicant Notice, please send an email to [email protected] with the subject line, “Applicant Privacy Notice”.