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California Consumer Privacy Act (“CCPA”) – Employee/APPLICANT Notice

This notice describes the categories of personal information (“PI”) collected by Davidson Hotel Company LLC d/b/a Davidson Hospitality Group (“Company”) and the purposes for which Consumer PI may be used. We are providing this notice to you in accordance with California Civil Code Sec. 1798.100(b).  For additional information about the Company’s data privacy practices, please review our privacy policy.

 

Categories of Personal Information Collected

 

Identifiers and Contact information. This category includes names, addresses, telephone numbers, mobile numbers, email addresses, dates of birth, Social Security numbers, drivers license or state identification numbers, bank account information, and other similar contact information and identifiers.

 

Protected classification information. This category includes characteristics of protected classifications under California or federal law.

 

Internet or other electronic network activity information. This category includes without limitation:

  • all activity on the Company’s information systems, such as internet browsing history, search history, intranet activity, email communications, social media postings, stored documents and emails, usernames and passwords
  • all activity on communications systems including phone calls, call logs, voice mails, text messages, chat logs, app use, mobile browsing and search history, mobile email communications, and other information regarding an Employee’s use of company-issued devices

Geolocation data. This category includes GPS location data from company-issued mobile devices and company-owned vehicles.

 

Audio, electronic, visual, thermal, olfactory, or similar information. This category includes, for example, information collected from cameras and similar devices, and/or thermometers.

 

Biometric information. This category includes fingerprint scans and related information, and certain wellness metrics.

 

Professional and employment-related information. This category includes without limitation:

  • data submitted with employment applications including salary history, employment history, employment recommendations, etc.
  • background check and criminal history;
  • work authorization
  • fitness for duty data and reports
  • symptoms and other indicators of exposure to COVID-19
  • travel information and information regarding close contacts
  • performance and disciplinary records
  • salary and bonus data
  • benefit plan enrollment, participation, and claims information
  • leave of absence information including religious and family obligations, physical and mental health data concerning employee/applicant and his or her family members

Education information. This category includes education history.

 

Inferences drawn from the PI in the categories above. Engaging in human capital analytics, including but not limited to, identifying certain correlations about individuals and success on their jobs, analyzing data to improve retention, and analyzing employee preferences to inform HR policies, programs and procedures

 

Sensitive Personal Information. This category includes sensitive personal information such as:

  • social security, driver’s license, state identification card, or passport number
  • financial account information that allows access to an account, including log-in credentials, financial account numbers, passwords, etc.
  • precise geolocation
  • racial or ethnic origin, religious or philosophical beliefs, or union membership
  • content of mail, email, and text messages (unless the Company is the intended recipient of the communication)
  • genetic data
  • biometric information for the purpose of uniquely identifying a consumer
  • health information
  • information concerning sex life or sexual orientation

 

Purposes Personal Information is Used

  • Collect and process employment applications, including confirming eligibility for employment, background and related checks, checks regarding fitness for duty, onboarding, and related recruiting efforts
  • Processing payroll and employee benefit plan and program design and administration including enrollment and claims handling, and leave of absence administration
  • Maintaining personnel records and record retention requirements
  • Communicating with employees/applicants and/or employees’ emergency contacts and plan beneficiaries
  • Complying with applicable state and federal labor, employment, tax, benefits, workers compensation, disability, equal employment opportunity, workplace safety, and related laws, guidance, or recommendations
  • Preventing unauthorized access to, use, or disclosure/removal of the Company’s property, including the Company’s information systems, electronic devices, network, and data
  • Ensuring and enhancing employee productivity and adherence to the Company’s policies
  • Investigating complaints, grievances, and suspected violations of Company policy
  • Design, implement, and promote the Company’s diversity and inclusion programs
  • Facilitate the efficient and secure use of the Company’s information systems
  • Ensure compliance with Company information systems policies and procedures
  • Improve safety of employees, applicants, customers and the public with regard to use of Company property and equipment
  • Improve efficiency, logistics, and supply chain management
  • Improve accuracy of time management systems
  • Evaluate an individual’s appropriateness for a particular position at the Company, or promotion to a new position
  • Customer engagement and other legitimate business purposes

Retention. We retain your personal information for as long as is necessary to process your application for employment, process your payroll, administer your benefits, etc. and in accordance with the Company’s data retention schedule.  We may retain your personal information for longer if it is necessary to comply with our legal or reporting obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, enforce our legal agreements and policies, address other legitimate business needs, or as permitted or required by applicable law.  We may also retain your personal information in a deidentified or aggregated form so that it can no longer be associated with you.  To determine the appropriate retention period for your personal information, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we collect or process your personal information; and applicable legal requirements.  Personal information does not include certain categories of information, such as publicly available information from government records, information that you make available to the public, and deidentified or aggregated consumer information.

Disclosure.  To carry out the purposes outlined above, the Company may disclose personal information to service providers or other third parties, such as background check vendors, third-party staffing vendors, information technology vendors, outside legal counsel, and state or federal governmental agencies.  The Company does not sell or share, as those terms are defined under applicable law, the above categories of personal information. The Company may add to the categories of personal information it collects and the purposes for which it uses that information.  The Company will inform you in the event it does so.

 

California Applicants Only: I understand the Company may obtain, without using the services of a third party investigative consumer reporting agency, public records pertaining to my character, general reputation, personal characteristics or mode of living during its evaluation of my application for employment and, if employed, during my employment. By checking the following box, I waive my right to receive copies of public records obtained by the Company.

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