CSI Companies – California Consumer Privacy Act (CCPA) Policy

Privacy of Personal Information

Certain privacy protections afforded to California residents under the CCPA, as amended, apply to employment-related personal information employers collect from job applicants, employees, and independent contractors.  The applicable protections in the employment context are:

1. Employers must safeguard the personal information it collects from job applicants, employees, and independent contractors; and

2. Employers must disclose to job applicants, employees, and independent contractors the categories of personal information it collects and the business purpose for collecting it.

Safeguarding Personal Information

It is CSI’s philosophy and policy to keep secure and safeguard all personal information that job applicants, employees, and independent contractors provide to CSI at any stage of the employment relationship.  Additionally, CSI will only collect personal information that is required to pursue its business operations and to comply with government reporting and disclosure requirements.  Furthermore, CSI will not sell your collected data.  

All pre-employment, current employment, and post-employment personal information is considered highly confidential.  Such information that CSI collects is physically maintained in locked, secure areas to which CSI limits access to personnel who have a business need for such access.  Personal information used in business system applications will be safeguarded under CSI’s proprietary electronic transmission and network policies and security systems.

CSI is required by certain laws to maintain certain post-employment personal information on file following the termination of the employment relationship.  Such post-employment information is safeguarded in the same manner as pre-employment and current employment personal information.

CSI provides training to its employees who have a business need to access personal information on the proper protocol in maintaining the confidentiality and security of personal information.  If an employee becomes aware of a material breach in maintaining the confidentiality or security of his or her personal information, the employee should report the incident to a representative of the human resources department.  The human resources department has the immediate responsibility to investigate the incident and take corrective action.

Collected Information

CSI collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular consumer or device.  In particular, CSI collects the following categories of personal information protected by the CCPA:

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
• Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
• Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
• Biometric Information
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements 
• Geolocation Data
• Sensory Information: audio, electronic, visual, thermal, olfactory, and similar information 
• Employment Information: professional or employment-related information 
• Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Purpose of Collecting This Information

We may use the categories of personal information listed above for the purposes described in our Privacy Policy. 

CSI collects this information for use in business operations, employment verification and decision-making, payroll, benefits administration, responses to law enforcement requests, in preparation of compulsory tax returns or government agency reports, and otherwise as required or permitted by applicable law, court order, or regulation. CSI does not sell the data we collect.

The personal information described in this policy may be disclosed to third parties such as payroll companies, insurance providers, and benefits administrators.  CSI may also share this information with clients when placing an employee on assignment.  CSI requires the client to execute a non-disclosure agreement before CSI will provide to the client any employee’s personal information.

In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table:

Sources of Personal Information

We may have obtained personal information about you from various sources, as described below. 

Data shared with third parties

We may share your data with third-parties in relation to employment opportunities, employment, un-employment, or payroll processing as required by our business processes or by request from a government entity. Your data may also be shared with third-party marketing and service providers to improve services offered or in relation to targeted communications to you such as collecting feedback from a job assignment or interview process. 

Policy Changes

CSI may periodically update or amend this CCPA Policy, whether due to changes in the law or changes in procedure.  CSI reserves the right to make such updates or amendments as it deems appropriate or necessary.  If the policy is updated or amended, current employees and contractors can request a copy of the most current version.

Requesting a Removal

To request a copy of what personal data we have stored, how it has been used or to request a removal of your data from our systems you can email us your request or mail a request to our corporate headquarters.

Email: ccpa@thecsicompanies.com

Phone: 888.341.3586

Written Requests

ATTN: HR – CCPA

9995 Gate Parkway N., Ste. 100

Jacksonville, FL, 32246

Please note, we may attempt to verify your identity through the email address or telephone number associated with your use of our services prior to fulfilling any such request and reserve the right to deny a request where we are unable to satisfactorily complete this process.

Verifying Requests 

To help protect your privacy and maintain security, we will take steps to verify your identity and proof California residency before granting you access to your personal information or complying with your request.  We require that you to provide verifiable information by providing a government issued ID and/or utility bill: full name, street address, city/state and zip/postal code.  In addition, if you do not wish to not share your personal information through means of government issued identification and you ask us to provide you with specific pieces of personal information, we will require you to sign a notarized declaration under penalty of perjury, that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access or deletion request on your behalf (a) we may require you to provide the authorized agent notarized written permission to do so, and (b) for deletion requests, we may require you to verify your own identity directly with us (as described above).

Additional Information

If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us.  To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request.  Please contact ccpa@thecsicompanies.com or 888.341.3586 to request this Statement in an alternative format.

Last Updated: 4/7/2021