Notice to Job Applicants Residing in California
Updated June 7, 2023
This notice applies to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household such as your real name, alias, postal address, email address, social security number, driver’s license number, passport number, or other similar identifiers (“personal information”). Personal information does not include publicly-available information and certain other information that is regulated by other applicable laws.
What Information Do We Collect
We have collected the following categories of personal information from job applicants in the last twelve (12) months:
- Personal information provided by you, including first and last name, address, email address, phone number, gender, and date and place of birth.
- Personal information provided by you regarding your working skills, education, certifications, curriculum vitae and employment qualifications, including information provided by previous employers and other references, if permitted under applicable law.
- Personal information provided by you when choosing to complete your professional profile in any recruiting platform utilized by us, including voluntarily updating your professional experience, business title, education, skills, etc.
- Personal information obtained from a third-party when performing authorized reference checks, background checks, or verifying personal information you provided to us, if permitted under applicable law.
We have collected the following categories of sensitive personal information from job applicants in the last twelve (12) months:
- EEO Data
- I-9 identification data
- Passport information
Our sources for this information:
- We receive this information directly from you when you apply for a position or when communicating with us
- Some information is automatically collected when you visit our websites or use our mobile applications
Our business purposes for collecting this information:
Collecting and using personal information is necessary to complete necessary applicant functions including but not limited to employee file creation, payroll, background check screening, I-9/E-Verify requirements. We use this information to respond to your requests, inform you about our company and events, and to send you advertisements. It also helps us to improve our business, authenticate you, prevent and detect fraud and potential security issues, and to fulfill our legal and regulatory obligations.
Third parties we share this information with:
- Our trusted third-party service providers and affiliates who provide a service to us or assist us with facilitating job applications; including Workday as our HRIS and applicant tracking system
- Our auditors, consultants, accountants, attorneys and others providing advice to us
- Any other party where we have obtained your consent or authorization
We will retain your information for a period reasonably necessary to evaluate job applications, and if you are hired, information obtained may be moved to your employee record. Unless required by applicable law, hiring records of non-hired individuals are retained until no longer necessary to retain your personal information, at such time we will delete or anonymize it.
Right to Know
You have the right to request that we disclose certain information to you about our collection of your personal information. Such information shall cover the 12-month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following:
- The categories of personal information we have collected about you
- The categories of sources from which we have collected your personal information
- Our business or commercial purpose(s) for collecting or selling your personal information
- The categories of third parties with whom we have shared your personal information; and
- The specific pieces of personal information we have collected about you
- What personal information was sold/shared and to whom.
You have the right to request that we disclose certain information to you about our disclosures and sales of your personal information. Such information shall cover the 12-month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following:
- The categories of personal information we have collected from you
- The categories of personal information we have sold about you and the categories of third parties to whom we sold such information, by category or categories of personal information for each category of third parties to whom the personal information was sold; and
- The categories of personal information that we disclosed about you for a business purpose
- What personal information was sold/shared and to whom.
Right to Opt-Out
We do not sell or share your personal information now and have no plans to start, however, we are required to let you know that you have the right to opt-out of the sale or sharing of your personal information if we ever engage in such activity.
Right to Delete
You have the right at any time to request that we delete your personal information. However, in some cases we cannot delete all or some of your personal information as required or permitted by applicable laws.
Right to Correct
You have the right at any time to request that inaccurate personal information collected by us be corrected. In addition, certain websites and applications we provide may permit you to access, review, and change your personal information by logging in and updating your account information. Please note that if you change or correct information after submitting it, such changes will be visible to us.
Right to Non-Discrimination
We will not discriminate against you for exercising your rights under the CCPA with respect to your application for employment. Further, we will not retaliate against you in any way for exercising your rights under the CCPA.
How to Contact us to Exercise Your Rights
To submit a request to exercise your “Right to Know” or “Right to Delete” or “Right to Correct” rights provided in this notice, please email firstname.lastname@example.org or MyHR-Americas@christies.com. We will evaluate the request and take action where required to do so.
We will confirm receipt of your request within 10 business days and will provide information about how we will process your request. We endeavor to respond to your request as soon as we can, within the timeframes permitted under the CCPA. If we are not able to respond to your request within 45 days, we will let you know that we may require additional time (up to 90 total days).
Verification of Requests and Authorized Agents:
We may have to verify your identity when you contact us to exercise your “Right to Know” or your “Right to Delete.” Our verification process may vary depending on the nature of your request. However, generally, we will verify your request by asking you to:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized agent.
- 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 that the personal information relates to you.
You may also use an authorized agent to exercise your rights on your behalf. If you wish to use an authorized agent to make a request on your behalf, unless you have provided the authorized agent with power of attorney, we may require that: (1) you provide your authorized agent signed permission to do so; (2) you verify your identity; and (3) you confirm that you have provided the authorized agent permission to submit the request. We may deny any request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.
Your authorized agent may make a request on your behalf by contacting us at email@example.com or MyHR-Americas@christies.com.
Please note that in most cases we are not able to respond to more than two “Right to Know” requests from a consumer in any 12-month period.