PCL and its subsidiaries and affiliated companies (“Company”) take your privacy seriously. We want you to know how we collect, use, and disclose your personal information.
Assistance For the Disabled
- The categories of personal information we collect about you
- The categories of sources from which we collect your personal information
- The purposes for which we use your personal information
- How we may disclose your personal information
- How long we keep your personal information
- Your privacy rights and how to exercise them
Scope of Application
“Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a job applicant.
1) THE CATEGORIES OF PERSONAL INFORMATION WE COLLECT
- Identifiers, for example: real name, alias, telephone number, postal address, e-mail address, signature, bank account name and number for direct deposits, and photographs
- Professional or Employment-Related Information, for example: educational institutions attended, degrees and certifications, licenses, work experience and previous employers, professional memberships and affiliations, union representation, seniority, training, employment start and ending dates, and job title
- Compensation and benefits information, for example: salary, bonus and commission, equity compensation information as disclosed by you
- Non-public educational information, for example: academic transcripts
- Sensory or Surveillance Data, for example: voicemails, recordings of meetings or video-conferences, and footage from video surveillance cameras
- Preferences, for example, hobbies and leisure activities, membership in voluntary/charitable/public organizations, and preferences regarding work tools, travel, hours, food for company events, etc.
- Characteristics of Protected Classifications Under California or Federal Law for employees, for example: race, age, national origin, disability, sex, and veteran status as necessary to comply with legal obligations and to support diversity and inclusion programs; disability, medical condition, and pregnancy, childbirth, breastfeeding, and related medical conditions, as necessary to comply with Federal and California law related to leaves of absence and accommodation; and marital and familial status as necessary to provide benefits to employees and for tax purposes
- Sensitive identifiers, for example: Social Security, driver's license, state identification card, or passport number
- Biometric information, for example, a fingerprint for a biometric timeclock
- Login credentials, for example: login credentials to an online account owned or subscribed-to by Company or as necessary to review personal communications as described in the preceding bullet point
- Religion, for example if volunteered by an employee in support of the employee’s request for a religious accommodation
2) THE CATEGORIES OF SOURCES FROM WHICH WE COLLECT YOUR PERSONAL INFORMATION
- You, for example, in your application, forms you fill out for us, assessments you complete, surveys you submit, and any information you provide during the course of your relationship with us
- Your family members with respect to their own personal information
- Internally generated, for example, Company may generate performance ratings, evaluations, hours worked, and other information about you
- Third parties, for example, job references, business partners, professional employer organizations or staffing agencies, insurance companies
- Public internet sources, for example, social media, job boards, public profiles, and other public online sources
- Public records, for example, court records, and credentialing and licensing organizations
- Automated technologies on Company’s electronic resources, for example, to track logins and activity across Company network
- Government or administrative agencies, for example, law enforcement, public health authorities, California Department of Industrial Relations, Employment Development Department
3) THE PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION
Managing Personnel / Administration
- To set up and manage an applicant record
- To manage personnel and workforce matters
- To fulfill recordkeeping and reporting responsibilities
- For recruitment
- To make business travel arrangements
- To manage workforce-related emergencies, including health emergencies
- To conduct surveys
Monitoring, Security, and Compliance
- To monitor use of Company information systems and other electronic resources or information systems
- To administer Company’s ethics hotline
- To protect the safety and security of Company’s facilities, including preventing illicit activity
- To report suspected criminal conduct to law enforcement and cooperate in investigations
- To control access to secure facilities
- To monitor compliance with Company policies
Conducting Our Business
- To engage in marketing, advertising, and promotion
- For communications with prospective, current, and former applicants
- For customer service purposes
- To enable Company to comply with client contractual obligations
- To manage business expenses and reimbursements
- To engage in project management
- To conduct product and service training
- To conduct research and development
- For event planning
- To engage in crisis management
Miscellaneous Other Purposes
- To manage and operate information technology and communications systems, risk management and insurance functions, budgeting, financial management and reporting, and strategic planning
- To manage litigation involving Company, and other legal disputes and inquiries and to meet legal and regulatory requirements
- In connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of Company or any of its subsidiaries or affiliates
- To manage licenses, permits, and authorizations applicable to Company’s business operations
- To protect the rights, property, or safety of Company, HR Individuals, customers or others.
Purposes Specific to Certain Categories of Applicants’ Personal Information
We may use the categories of Applicants’ personal information listed in this Section for the purposes stated below:
Purposes For Using Applicants’ Biometric Information:
- Company may use biometric technology for security purposes to verify the identity of an individual entering certain Company facilities.
Purposes For Using Applicants’ Health Information:
- To the extent necessary to comply with Company’s legal obligations, such as to accommodate disabilities
- To conduct a direct threat analysis in accordance with the Americans with Disabilities Act and state law
- To conduct fitness-for-duty examinations
- To provide a wellness program
- To respond to a medical emergency
Purposes For Using Applicants’ Personal Communications:
- For purposes of legitimate Company investigations and, to the extent required by law, with your authorization.
Purposes For Using Applicants’ Religion:
- Company may use applicants’ religion to respond to, and manage, an employee’s request for an accommodation on the basis of religion.
Purposes For Using Applicants’ Protected Categories of Information:
Company collects information about race, age, national origin, disability, sex, and veteran status as necessary to comply with legal obligations, including the reporting requirements of the federal Equal Employment Opportunity Act, the federal Office of Contracting Compliance Programs (applicable to government contractors), and California’s Fair Employment and Housing Act. Company also collects information about disability status to the extent an applicant may need special assistance during emergencies from Company or from first responders.
Company also collects the following characteristics (in addition to those listed above) for its diversity and inclusion programs (including analytics): (a) religion, (b) sex, (c) gender, (d) pregnancy, (e) childbirth, (f) breastfeeding, or related medical conditions, (g) sexual orientation, (h) disability, (i) gender identity, (j) gender expression, (k) marital status, (l) age, (m) familial status, or (n) ancestry.
Company collects personal information about membership in protected categories on a purely voluntary basis, except where required by law, and uses the information only in compliance with applicable laws and regulations.
A. Deidentified Information
At times, Company converts personal information into deidentified information using reasonable measures to ensure that the deidentified information cannot be associated with the individual (“Deidentified Information”). Company maintains Deidentified Information in a deidentified form and does not attempt to reidentify it, except that Company may attempt to reidentify the information solely for the purpose of determining whether its deidentification processes ensure that the information cannot be associated with the individual. Company prohibits vendors, by contract, from attempting to reidentify Company’s Deidentified Information.
4) HOW WE MAY DISCLOSE YOUR PERSONAL INFORMATION
Company generally maintains information related to its potential personnel as confidential. However, from time to time, Company may have a legitimate business need to disclose personnel information for one of the purposes listed in Section 2, above, to one or more of the categories of recipients listed below. In that event, Company discloses your personal information and/or sensitive personal information only to the minimum extent necessary to achieve the purpose of the disclosure and only if the disclosure is permitted by the CPRA and other applicable laws.
- Service providers and contractors: Company discloses your personal information to service providers and contractors to assist us in meeting our business needs and contractual and legal obligations.
- Company discloses your personal information to service providers and contractors only subject to written contracts in compliance with the CPRA and any other applicable law.
- Service providers and contractors include auditors, administrative service providers, law firms, travel agencies, benefits providers, and any other entity providing services to Company.
- Affiliated companies: Other companies within the PCL family of companies.
- Clients: Company discloses your person information to clients to assist us in meeting our business needs and contractual and legal requirements.
- Business partners: For example, Company might disclose your business contact information to a joint venture partner with which you will be working.
- Government or administrative agencies: These may include, for example:
- Internal Revenue Service to pay taxes
- Employment Development Department as required for state payroll taxes and to respond to unemployment or state disability insurance claims
- National Labor Relations Board, for example, to notify the NLRB that an employee is represented by a union
- OSHA/CalOSHA as required to report work-related death or serious injury or illness
- Department of Fair Employment and Housing as required to respond to employment charges; and
- California Department of Industrial Relations as required to resolve workers’ compensation claims
- Public: Company may disclose your personal information to the public as part of a press release, for example, to announce promotions or awards. If you do not want your personal information in press releases, please contact the Communications department at NAThomas@pcl.com. Company does not disclose sensitive personal information to the public.
- Required Disclosures: We may be required to disclose personal information (a) in a court proceeding, (b) in response to a court order, subpoena, civil discovery request, other legal process, or (c) as otherwise required by law.
- Legal Compliance and Protections: We may disclose personal information when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of Company, our users, or others.
No sales and no “sharing”, i.e., disclosure for cross-context behavioral advertising:
Company does not sell the personal information of any applicants nor disclose their personal information for cross-context behavioral advertising.
5) HOW LONG WE KEEP YOUR PERSONAL INFORMATION
Company keeps your personal information no longer than necessary for the purposes described in Section 2 above and in accordance with our Records Retention Policy.
6) YOUR PRIVACY RIGHTS AND HOW TO EXERCISE THEM
a. Your California Privacy Rights
- Subject to applicable law, applicants have the following rights:
- Right to Know: You have the right to submit a verifiable request for copies of specific pieces of your personal information collected in the preceding 12 months and for information about the Company’s collection, use, and disclosure of your personal information during that same 12-month time period. Please note that the CPRA’s right to obtain copies does not grant a right to the whole of any document that contains personal information, but only to copies of “specific pieces” of personal information. Moreover, HR Individuals have a right to know categories of sources of personal information and categories of external recipients to which personal information is disclosed, but not the individual sources or recipients. Company does not always track individualized sources or recipients.
- Right to Delete: You have the right to submit a verifiable request for the deletion of personal information that you have provided to Company.
- Right to Correct: You have the right to submit a verifiable request for the correction of inaccurate personal information maintained by Company, taking into account the nature of the personal information and the purposes of processing the personal information.
b. How to Exercise Your Rights
Company will respond to requests know, delete, and correct in accordance with applicable law if it can verify the identity of the individual submitting the request. You can exercise these rights in the following ways:
- Call (800) 461-9330
- Email firstname.lastname@example.org
c. How We Will Verify Your Request:
The processes that we follow to verify your identity when you make a request to know, correct, or delete are described below. The relevant process depends on how and why the request is submitted.
If you submit a request by any means other than through a password-protected account that you created before the date of your request, the verification process that we follow will depend on the nature of your request as described below:
- Requests to Know Categories or Purposes: We will match at least two data points that you provide with your request, or in response to your verification request, against information about you that we already have in our records and that we have determined to be reliable for purposes of verifying your identity. Examples of relevant data points include your mobile phone number, your zip code, or your employee identification number.
- Requests to Know Specific Pieces of Personal Information: We will match at least three data points that you provide with your request, or in response to our request for verification information, against information that we already have about you in our records and that we have determined to be reliable for purposes of verifying your identity. In addition, we may require you to sign a declaration under penalty of perjury that you are the individual whose personal information is the subject of the request.
- Requests to Correct or Delete Personal Information: Our process for verifying your identity will depend on the sensitivity (as determined by Company) of the personal information that you ask us to correct delete. For less sensitive personal information, we will require a match of two data points as described in Point No. 1, above. For more sensitive personal information, we will require a match of three data points and a signed declaration as described in Point No. 2, above.
We have implemented the following additional procedures when verifying the identity of requestors:
- If we cannot verify your identity based on the processes described above, we may ask you for additional verification information. If we do so, we will not use that information for any purpose other than verification.
- If we cannot verify your identity to a sufficient level of certainty to respond to your request, we will let you know promptly and explain why we cannot verify your identity.
d. Authorized Agents
If an authorized agent submits on your behalf a request to know, correct or delete, the authorized agent must submit with the request either (a) a power of attorney, signed by you, that is valid under California law; or (b) another document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you or your authorized agent to follow the applicable process described above for verifying your identity. You can obtain “Authorized Agent Designation” form by contacting us at (800) 461-9330.
e. Company’s Non-Discrimination And Non-Retaliation Policy
Company will not unlawfully discriminate or retaliate against you for exercising your rights under the California Privacy Rights Act.