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.

Sale of Data

CSI values the privacy of your data and as such, does not engage in the practice of selling consumer data. CSI has not sold data to any third-parties within the last 12 months.

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:

Purposes Categories of Personal Information 
Performing services, including maintaining or servicing accounts, providing services, processing or fulfilling placement services, verifying candidate and customer information, processing payroll, processing expenses, advertising or marketing services, providing analytics services, or providing similar services
  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Biometric Information
  • Online Activity
  • Geolocation Data
  • Sensory Information
  • Employment Information
  • Education Information
  • Inferences
Auditing related to current interactions with you, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Biometric Information
  • Online Activity
  • Geolocation Data
  • Sensory Information
  • Employment Information
  • Education Information
  • Inferences
Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Biometric Information
  • Online Activity
  • Geolocation Data
  • Sensory Information
  • Employment Information
  • Education Information
  • Inferences
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Biometric Information
  • Online Activity
  • Geolocation Data
  • Sensory Information
  • Employment Information
  • Education Information
  • Inferences
Debugging to identify and repair errors that impair existing intended functionality
  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Biometric Information
  • Online Activity
  • Geolocation Data
  • Sensory Information
  • Employment Information
  • Education Information
  • Inferences
Undertaking internal research for technological development and demonstration
  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Biometric Information
  • Online Activity
  • Geolocation Data
  • Sensory Information
  • Employment Information
  • Education Information
  • Inferences
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, provided, or controlled by us
  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Biometric Information
  • Online Activity
  • Geolocation Data
  • Sensory Information
  • Employment Information
  • Education Information
  • Inferences

 

Sources of Personal Information

We may have obtained personal information about you from various sources, as described below. 
Categories of Sources of Data Collection Categories of Personal Information
Directly from you, such as when you contact us
  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Biometric Information
  • Online Activity
  • Geolocation Data
  • Sensory Information
  • Employment Information
  • Education Information
  • Inferences
From your devices, such as when you visit our Site
  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Biometric Information
  • Online Activity
  • Geolocation Data
  • Sensory Information
  • Employment Information
  • Education Information
  • Inferences
Our Affiliates
  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Biometric Information
  • Online Activity
  • Geolocation Data
  • Sensory Information
  • Employment Information
  • Education Information
  • Inferences
Vendors who provide services on our behalf
  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Biometric Information
  • Online Activity
  • Geolocation Data
  • Sensory Information
  • Employment Information
  • Education Information
  • Inferences
Our joint marketing partners
  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Biometric Information
  • Online Activity
  • Geolocation Data
  • Sensory Information
  • Employment Information
  • Education Information
  • Inferences
Social networks
  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Biometric Information
  • Online Activity
  • Geolocation Data
  • Sensory Information
  • Employment Information
  • Education Information
  • Inferences
Online advertising services
  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Biometric Information
  • Online Activity
  • Geolocation Data
  • Sensory Information
  • Employment Information
  • Education Information
  • Inferences
Government entities
  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Biometric Information
  • Online Activity
  • Geolocation Data
  • Sensory Information
  • Employment Information
  • Education Information
  • Inferences
Consumer data resellers
  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Biometric Information
  • Online Activity
  • Geolocation Data
  • Sensory Information
  • Employment Information
  • Education Information
  • Inferences

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. 

Categories of Third-Party

Categories of Data Shared with Third Parties

Analytics and Optimization

  • Job Postings
  • Job Applications
  • Site Activity and Usage
  • Feedback

Cloud Storage, Computing Platforms and Associated Tools and
Software Providers

  • Diversity and Inclusion Information
  • Profile Information
  • Support History
  • Job Applications
  • Login Information
  • Online Activity
  • User Feedback
  • Content You Contributed

Customer and Candidate Relationship Management

  • Job Postings
  • Profile Information
  • Protected Classifications
  • Marketing Activity
  • User Feedback

Information Technology Service and Support Providers

  • Geolocation Data
  • Mailing Address
  • Full Name
  • Signature
  • Username Identifiers

Email and Email Delivery Providers

  • Profile Information
  • Job Applications
  • Job Interests
  • Marketing Activity
  • User Feedback

Employers

  • Personal Identifiers
  • Job Applications
  • Profile Information
  • Salary Requirements
  • Employment History
  • Education History
  • Criminal Background Check Results (pass/fail)
  • Drug Screening Results (pass/fail)

Payroll Processing, Financial Transaction, Accounting, and
Audit providers

  • Personal Identifiers
  • Full Name
  • Mailing Address
  • Salary Information
  • Tax Exemptions
  • Banking Information

Government entities

  • Data Subject to Cal. Civ. Code § 1798.80
  • Identifiers
  • Protected Classifications
  • Biometric Information
  • Geolocation Data
  • Employment Information
  • Education Information 
  • Salary Information
  • Performance Information

 

Exercising Your CCPA Rights To:

Know, Delete or Correct Your Personal Information

To exercise your right to know, delete, or correct your personal information, please submit a verifiable consumer request to CSI by one of the following:

CSI will provide this information for the 12-month period preceding your request free of charge.

Limit the Use and Disclosure of Your Sensitive Personal Information

Equal Employment Opportunity/Demographic Data. CSI collects demographic data as part of our commitment to inclusivity and fairness in the hiring process. Sharing of this data with us is optional and includes the following categories:

      • Age (Birth year)
      • Race & Ethnicity
      • Gender
      • Disability status
      • LGBTQ+ Community Membership
      • Arrest or conviction history
      • Veteran status

To limit the use of your demographic data as described above:

      • Call our designated toll-free telephone number for CCPA requests: 888.341.3586
 
Opt-Out of Selling or Sharing My Personal Information

To exercise the right to opt-out of selling or sharing your personal data, you (or your authorized representative) may submit a request to us by:

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.

 

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 privacy@csicompanies.com or 888.341.3586 to request this Statement in an alternative format.

Last Updated: 8/27/2024

This website collects data, including information provided by you and information we collected using cookies. By continuing to use our website, you consent to our privacy policy

This website collects data, including information provided by you and information we collected using cookies. By continuing to use our website, you consent to our privacy policy