Privacy Notice for California Employees and Job Applicants
Effective Date: January 1, 2020
Last Updated: July 1, 2024
This Privacy Notice for California Employees and Job Applicants supplements the information contained in other corporate policies concerning privacy of information and applies solely to employees or job applicants who reside in the state of California ("you"). Enlyte Group, LLC., including its related companies Mitchell International, Inc. Genex Services, LLC, Coventry Health Care Workers Compensation, Inc., and their subsidiaries (collectively “Company”) adopt this notice to comply with the California Consumer Privacy Act (CCPA) and any amendments, and any terms defined in the CCPA have the same meaning when used in this notice.
Information We Collect
The Company collects information from our employees and job applicants that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular employee or job applicant ("Personal Information"). In particular, the Company has collected the following categories of Personal Information from its employees and job applicants within the last twelve (12) months:
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Category
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Examples
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Purpose
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Third Parties Shared
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Identifiers
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A real name, alias, postal address, Internet Protocol address, email address, Social Security number, passport number, driver's license number, or other similar identifiers
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(a) Performance of a contract |
(a) Human resources information service providers |
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Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) |
A name, Social Security number, address, telephone number, passport number, driver's license or state identification card number, education, employment, employment history, or financial information |
(a) Performance of a contract |
(a) Human resources information service providers |
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Protected classification characteristics under California or federal law |
Age (40 years or older), race, sex/gender, veteran or military status |
(a) Necessary for our legitimate interests |
(a) Human resources information service providers |
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Internet or other similar network activity |
Browsing history, search history, information on your interaction with a website, application, or advertisement |
(a) Necessary for our legitimate interests |
N/A |
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Geolocation data |
Physical location or movements |
(a) Necessary for our legitimate interests |
(a) Marketing support service providers |
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Professional or employment-related information |
Current or past job history or performance evaluations |
(a) Necessary for our legitimate interests |
(a) Human resources information service providers |
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Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) |
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades and transcripts |
(a) Necessary for our legitimate interests |
(a) Human resources information service providers |
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Inferences drawn from other personal information |
Profile reflecting a person's preferences, characteristics, behavior, attitudes, abilities, and aptitudes |
N/A |
N/A |
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Sensitive personal information |
Personal information that reveals government IDs; information providing access to a financial account; racial or ethnic origin; personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. |
(a) Necessary for our legitimate interests |
(a) Human resources information service providers |
Personal Information does not include:
- Publicly available information from government records.
- Deidentified or aggregated information.
- Information excluded from the CCPA's scope, such as:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
The Company obtains the categories of Personal Information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete.
- Indirectly from you. For example, from observing your actions with computer systems, software or other products offered by the Company.
- Third Parties. For example, from third party vendors used for background checks.
Use of Personal Information
The Company may use or disclose the Personal Information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, to conduct payroll activities and timekeeping activities, administer benefits, or offer wellness programs.
- To investigate and help prevent fraud or otherwise ensure compliance with policies and procedures.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To help maintain the safety, security, and integrity of our systems, services, databases and other assets.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by the Company about our employees and job applicants is among the assets transferred.
The Company will not collect additional categories of personal information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Disclosure of Personal Information
We may share your personal information for business purposes by disclosing it to the categories of third parties identified in the chart above. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract.
We do not sell or share (as the term is defined in the CCPA1) your personal information. We also do not disclose or use sensitive personal information outside of the permissible uses identified within the CCPA.
1The CCPA defines “sharing” as communicating personal information to a third party for cross-context or targeted behavioral advertising.
Your Rights and Choices
You have rights regarding your personal information. This section describes the rights you have and explains how to exercise those rights.
Access to Specific Information
You may have the right to request that the Company disclose certain information to you about our collection and use of your personal information over the past 12 months, including:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you. • Our business or commercial purpose for collecting that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you.
- If we disclosed your personal information for a business purpose, identification of the personal information categories that each category of recipient obtained.
You may also have the right to receive a copy of the personal information the Company has collected about you in the past 12 months.
Deletion Request Rights
You may have the right to request that the Company delete any of your personal information that we collected from you and retained, subject to certain exceptions. If we are unable to comply with your request, we will provide a response explaining why your data cannot be deleted.
Correction Request Rights
You may have the right to request that the Company correct any inaccurate personal information we may hold about you. We will use commercially reasonable efforts to correct inaccurate personal information, taking into the account the nature of the personal information and the purpose for our processing.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights.
Retention Periods
We will generally retain information about you for so long as we have a legal or business purpose for it or a legal requirement to maintain it. The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you 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 require us to keep records for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Exercising Your Rights
To exercise your rights described above, please submit a request by either:
- Submitting a ServiceNow Request to People & Workplace via the Enlyte Enterprise Service Hub
- Emailing legal@enlyte.com
- Calling the toll-free number at 833-848-0124
We may need to validate your request and, to do so, we may ask you for additional information. Only you or an authorized agent may make a request related to your personal information. To designate an authorized agent, you must provide us with written permission to allow your authorized agent to act on your behalf. We may also verify the identity of your authorized agent.
Changes to This Privacy Notice
The Company reserves the right to amend this privacy notice at our discretion and at any time. When we amend this privacy notice, we post the updated notice on the People and Workplace Policies Page of the Company SharePoint site and update the notice's effective date.
Questions About This Privacy Notice
If you have any questions or comments about this notice or the ways in which the Company collects and uses your information, please contact:
Iris Sockel Mitrakos
VP, Associate General Counsel
iris.mitrakos@enlyte.com