NOTICE AT COLLECTION AND PRIVACY NOTICE FOR CURRENT, FORMER AND PROSPECTIVE EMPLOYEES RESIDING IN CALIFORNIA PURSUANT TO THE CALIFORNIA PRIVACY RIGHTS ACT

The California Privacy Rights Act of 2020, Cal. Civil Code § 1798.100 et seq., (“CPRA”) requires that Rausch Sturm LLP (“Rausch Sturm” or “we”) disclose the following information to you. This Privacy Notice for California employees (“Notice”) applies solely to current, former and prospective employees who reside in the State of California (“employees” or “you”). Any terms defined in the CPRA have the same meaning when used in this Notice.

Under California law our California employees have the following rights:

  1. The right to receive disclosure about our Information Collection Practices. This disclosure is provided below.
  2. The right to receive disclosure about our Information Disclosure Practices. This disclosure is provided below.
  3. The right to tell us not to sell your personal information. Rausch Sturm does not sell your personal information.
  4. The right to tell us not to share your personal information for behavioral or cross-context marketing purposes. Rausch Sturm does not share your personal information for this purpose.
  5. The right to tell us not to process your Sensitive Personal Information for purposes other than the purposes for which it was originally collected. Rausch Sturm only processes Sensitive Personal Information for the purpose for which it was originally collected.
  6. The right to request that we correct information that is incorrect. Please see below for how to exercise this right.
  7. The right to request a copy of Personal Information we collected about you during the past 12 months or, at your option, since January 1, 2022, subject to certain exceptions. Please see below for how to exercise this right.
  8. The right to request that we delete Personal Information subject to certain exceptions. Please see below for how to exercise this right.

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device (“personal information”). We collect and use personal information for human resources, employment, benefits administration, health and safety, and business related purposes and to be in legal compliance. Categories of personal information we typically collect or use:

  1. Identifiers such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
  2. Personal information categories such as name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, education, employment, employment history, bank account number, medical information. Some personal information included in this category may overlap with other categories.
  3. Protected anti-discrimination classification characteristics such as age, race, color, ancestry, national origin, citizenship, marital status, medical condition, physical or mental disability, sex, veteran or military status.
  4. Commercial information, including records of personal property;
  5. Internet or other similar network activity such as browsing history, search history, information on your interaction with company systems, websites, applications, etc.
  6. Geolocation data such as physical location or movements.
  7. Sensory data such as audio, electronic, visual, or similar information.
  8. Professional or employment-related information such as current or past job history or performance evaluations.
  9. Sensitive personal information such as Social Security, driver’s license, state identification card, or passport number, account log-in in combination with any required security or access code, password, or credentials allowing access to an account, racial or ethnic origin, religious or philosophical beliefs, union membership, citizenship or immigration status.

Rausch Sturm collects the above categories of Personal Information directly from employees; and some from third parties such as staffing partners and employment application references. We use Personal Information to:

  1. Comply with all applicable laws and regulations.
  2. Recruit and evaluate job applicants and candidates for employment based on skills and experience
  3. Conduct background checks.
  4. Manage your employment relationship with us, including for:
    1. onboarding processes;
    2. timekeeping, payroll, and expense report administration;
    3. employee benefits administration;
    4. employee training and development requirements;
    5. the creation, maintenance, and security of your online employee accounts;
    6. reaching your emergency contacts when needed, such as when you are not reachable or are injured or ill;
    7. workers' compensation claims management;
    8. employee job performance, including goals and performance reviews, promotions, discipline, and termination;
    9. other human resources purposes;
  5. Manage and monitor employee access to company facilities, equipment, and systems.
  6. Conduct internal audits and workplace investigations.
  7. Investigate and enforce compliance with and potential breaches of Company policies and procedures.
  8. Engage in corporate transactions requiring review of employee records, such as for evaluating potential mergers and acquisitions of the Company.
  9. Maintain commercial insurance policies and coverages, including for workers' compensation and other liability insurance.
  10. Perform workforce analytics, data analytics, and benchmarking.
  11. Administer and maintain the Company's operations, including for safety purposes.
  12. Exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents.
  13. We use and process Sensitive Personal Information to comply with laws including anti-discrimination laws and disability accommodation laws.

Rausch Sturm may disclose Personal Information of employees for a business purpose to service providers or contractors who assist us in administering our workforce including benefits providers; payroll and expense administrators; worker’s compensation vendors and government agencies; professional advisors such as attorneys, auditors and accountants; and, where appropriate, law enforcement or government regulators.

We do NOT sell employee Personal Information.

We do NOT share employee Personal Information with third parties for behavioral or cross-context marketing purposes.

Rausch Sturm will determine the length of time necessary for maintaining each category of personal information by the following criteria: contractual agreements with our clients; applicable federal, state and local laws; and the compatibility with the context in which the personal information was collected. We only intend to keep your personal information for as long as necessary consistent with these purposes, or as required by law.

If you would like to receive a copy of the information collected about you during the past 12 months or at your option since January 1, 2022, please contact hrinbox@rauschsturm.com or call 1-855-517-6279. Certain information will not be released to you because of legal restrictions or because the information is used for security purposes. You may make this request up to twice in any calendar year. We will acknowledge receipt of your request within 10 business days and provide a copy of your information in an easily readable format within 45 days. If we need an additional 45 days to compile your information we will let you know.

If you would like for us to delete information that we are permitted by law to delete, please contact hrinbox@rauschsturm.com or call 1-855-517-6279. We are not permitted to delete information that we need in order to operate our business, administer our employees, protect our legal obligations and rights, or to provide security for our employees, our systems and our company. You may make this request up to twice in any calendar year. We will acknowledge receipt of your request within 10 business days and honor your request within 45 days. If we need an additional 45 days to respond we will let you know.

We will not discriminate against you as a result of your exercise of any of these rights.

We reserve the right to amend this Notice at our discretion at any time. When we make changes to this Notice, we will post the updated notice on our website and update the Notice’s Last Updated date.

Effective Date: January 1, 2023
Last Updated: January 1, 2024

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