> Privacy Policy
> California Consumer Privacy Act
> GDPR Privacy Policy
> Privacy Shield Policy
> Accessibility
Lowenstein Sandler LLP
California Consumer Privacy Act Notice
California Residents: Employees and Job Applicants
Last Updated: May 1, 2024
This California Consumer Privacy Notice applies to the personal information of job applicants and employees of Lowenstein Sandler LLP (“Lowenstein,” “we,” “us,” or “our”). Lowenstein will collect, collect, disclose, and otherwise process personal information for evaluation of job applicants, human resources, employment, benefits administration, health and safety, and other business-related purposes, and to comply with applicable laws and regulations.
1. The Personal Information We Collect, and How Long We Keep It
We will not sell or share (as defined in the CCPA) the personal information we collect in connection with your employment.
We may collect the categories of personal information (including sensitive information) listed in the tables below. The tables also list, for each category, our expected retention period, or as applicable, the criteria used to determine the retention period.
|
Personal Information Category
|
Retention Period
|
|
Identifiers, such as your full name, gender, date of birth, signature, home address, telephone numbers, email addresses, and emergency contact information
|
Termination + 4 Years
|
|
Protected classification characteristics under California or federal law (and not listed under “sensitive PI” below), such as marital status, age, national origin, ancestry, sex, and veteran or military status
|
Termination + 4 Years
|
|
Commercial information, such as records of personal property, or other purchasing or consuming histories or tendencies
|
N/A
|
|
Internet or similar network activity, such as browsing history, search history, and information regarding your interaction with an internet website application, or advertisement
|
N/A
|
|
Geolocation data, such as time and physical location related to use of an internet website, application, or device
|
N/A
|
|
Sensory or surveillance information, such as COVID-19 related temperature checks, call monitoring, or video surveillance
|
N/A
|
|
Professional or employment-related information, such as your job title, position, hire dates, work history, compensation, performance and disciplinary records, and vacation and sick leave records
|
Termination + 4 Years
|
|
Non-public educational information, such as academic and professional qualifications, educational records, and references
|
Termination + 4 Years
|
|
Dependent’s or other individual’s information, such as their full name, address, emergency contact number, or date of birth
|
Termination + 6 Years
|
|
Information related to immigration status, such as visa information, immigration status, and related documentation
|
3 Years after Hire Date or Termination + 1 Year (whichever is later by law)
|
|
Financial information, such as banking details, tax information, payroll information, and withholdings
|
7 Years
|
|
Inferences drawn from the above information, such as assessments and summaries about your qualifications, preferences, characteristics, attitudes, intelligence, abilities, and aptitudes
|
Termination + 4 Years
|
|
Sensitive Personal Information Category
|
Retention Period
|
|
ID Numbers, such as Social Security, driver’s license, state identification card, or passport number
|
3 Years after Hire Date or Termination + 1 Year (whichever is later by law)
|
|
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
|
N/A
|
|
Precise geolocation, i.e. data that that could locate you within a radius of 1,850 feet (a circle of about 242 acres, or the size of about 187 football fields)
|
N/A
|
|
Racial or ethnic origin
|
Termination + 4 Years
|
|
Religious or philosophical beliefs
|
Religious beliefs obtained from Optional/Self- Identification through Surveys:
Termination + 4 Years
|
|
Union membership
|
N/A
|
|
Contents of mail, email, or text messages that have not been directed to us
|
N/A
|
|
Genetic data
|
N/A
|
|
Biometric information, such as facial recognition, fingerprints, iris or retina scans, keystroke, or other physical patterns like [EXPLAIN]
|
N/A
|
|
Personal information collected and analyzed concerning your health, including health conditions (if relevant to your employment), job restrictions, workplace illness and injury information, and health insurance policy information
|
Info related to health insurance policy and accommodations: Termination + 4 Years
---
Info related to workers compensation claims:
Duration of employment + 30 years
|
|
Personal information collected and analyzed concerning your sex life, or sexual orientation
|
Sexual Orientation obtained from Optional/Self- Identification through Surveys:
Termination + 4 Years
|
|
Dependent’s or other individual’s sensitive information, such as their Social Security numbers and health information.
|
Termination + 6 Years
|
2. How We Obtain Your Personal Information
We receive your personal information mostly directly from you, but may also receive it from the following categories of sources:
- Publicly available sources;
- Your references;
- Companies that conduct background checks, screen for know your customer (KYC), anti-money laundering (AML), and/or other factors;
- Current and former employers, colleagues, customers, clients, recruiting agencies, or other professional contacts;
- Security cameras, time clocks, phone logs, GPS systems on company vehicles, and similar technology; and
3. Business Purposes for Collection and Use of Personal Information
Lowenstein collects, discloses, and otherwise processes the categories of personal information listed above to comply with applicable laws and regulations, and the following business purposes:
- Manage your employment relationship with us, including for:
- Evaluating your job application;
- Onboarding;
- Timekeeping, payroll, and expense report administration;
- Employee benefits administration;
- Employee training and development requirements;
- The creation, maintenance, and security of your online employee accounts;
- Reaching your emergency contacts when needed, such as when you are not reachable or are injured or ill;
- Workers’ compensation claims management; and
- Employee job performance, including goals and performance reviews, coaching, promotions, discipline, and termination.
- Manage and monitor employee access to company facilities, equipment, and systems;
- Conduct internal audits and workplace investigations;
- Investigate and enforce compliance with and potential breaches of Lowenstein policies and procedures;
- Engage in corporate transactions requiring review of employee records, such as for evaluating potential mergers and acquisitions of Lowenstein;
- Maintain commercial insurance policies and coverages, including for workers’ compensation and
other liability insurance;
- Perform workforce analytics, data analytics, and benchmarking;
- Administer and maintain Lowenstein operations, including for safety purposes;
- For client marketing purposes;
- Exercise or defend the legal rights of Lowenstein and its employees, affiliates, customers, contractors, and agents; and
- Comply with applicable laws and regulations; and
- Required Federal and State EEO and other compliance reporting.
4. What Kind of Personal Information We Disclose to Others
We may disclose the following categories of personal information to the following categories of service providers, contractors, and third parties for a business purpose:
|
Personal Information Category
|
Category of Third Parties
|
|
Name, address, telephone number(s) and email address(es); emergency contact names and telephone numbers; DOB; immigration status and identification, such as social security number; driver’s license number or passport number (1-9 Form); gender; gender identity or expression; marital status; dependent(s) name, address, telephone number(s); DOB, SSN.
An employment contract, offer letter or independent contractor agreement.
Salary and banking information for payroll purposes.
Resume or CV; and education information, such as colleges, certifications, degrees, GPA, graduation dates, and bar admission licensing information.
Optional self-identification: veteran status, disability status; nationality; religion; pronouns; foreign languages
|
HRIS/Payroll System
|
|
Immigration status and required identification, such as social security number; driver’s license number, passport number or any valid identification used for 1-9 Form.
|
HireRight
|
|
Name, address, telephone number(s) and email address(es).
|
Everbridge (Emergency Communication System)
|
|
Job application (including electronic or web-based applications), resume, CV, executive summaries from applicant or recruiter; professional biographies, LinkedIn profiles, business plans, deal sheets. These may include: salary desired; prior work history, including reason for leaving and supervisor name; references; referral source; familial relationships; bar admission licensing information.
|
Jobvite and viRecruit (Applicant Tracking and Recruiting Software)
|
|
Employee name, address, telephone number(s), email address, DOB, SSN gender, annual salary and medical information.
Dependent(s) DOB & gender
|
Unum (Life Insurance and Disability)
|
|
Name, email address, bank account number, or any other financial information.
|
Chrome River (Business Expense and Reimbursement Tool)
|
|
Name, email addresses and work phone numbers
|
eBilling Vendors
|
5. Your Privacy Rights
You have the following rights regarding your personal information:
- Right to Know: You have the right to know:
- The categories of specific personal information we collect, use, disclose, sell, and/or share; and
- The specific pieces of personal information we have collected from or about you.
- Right to Delete: You have the right to request deletion of your personal information. We will honor such request, but might not be able to fulfill your request if we (or our service providers) are required to retain your personal information.
- Right to Correct: You have the right to request that we correct inaccurate personal information about you. We will honor such request, but might not be able to fulfill your request if it is impossible to do so or would involve disproportionate effort, or if we have a good-faith, reasonable, and documented belief that a request to correct is fraudulent or abusive.
- Right to Opt-Out of the Sale or Sharing of Personal Information: You have the right to opt-out of the “sale” or “sharing” of your personal information. Please note, however, that we do not “sell” or “share” the personal information of our job applicants or employees as those terms are defined under the CCPA.
- Right to Restrict the Processing of Sensitive Personal Information: If we collect or process your sensitive personal information in order to infer characteristics about you, you have the right to restrict how we use and disclose such information. Please note, however, that we do not collect or process your sensitive personal information in order to infer characteristics about you.
- Anti-Retaliation Right: We are prohibited from discriminating against you for exercising any of the above rights.
- Right to Designate an Authorized Agent: If you submit a request to know or delete your personal information through the use of an authorized agent, we may require that you (i) provide the authorized agent written permission to act on your behalf, and (ii) verify their identity directly with us.
6. Exercising Your Privacy Rights
To exercise the rights described above, please submit a request to us by using the methods outlined below.
In order to fulfill your request, we may need you to (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information related to you.
We will confirm receipt of your request within then (10) business days of its receipt, and endeavor to respond within forty-five (45) calendar days of its receipt. If we require more time, we will notify you of the extension and provide an explanation of the reason for the extension in writing, and we will provide you with a response no later than ninety (90) calendar days of receipt of the request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We may charge a reasonable fee to process or respond to your requests if they are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for this decision and provide you with a cost estimate before completing your request.
7. Updates
This CCPA Employee Privacy Notice (the “Notice”) is effective as of the date of the “Last Update” stated at the top of this Notice. We may change this Notice from time to time with or without notice to you. By engaging or interacting with us after we make any such changes to this Notice, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, and without prejudice to the foregoing, our use of your personal information is governed by the Notice in current effect. Please refer back to this Notice on a regular basis.
8. How to Contact Us
If you have any questions about this Notice or need to access this Notice in an alternative format due to having a disability, please contact CCPA@lowenstein.com or 1-844-466-5060.
© 2024 Lowenstein Sandler LLP. All rights reserved.
