California Employee Privacy Notice

California Consumer Privacy Notice to

California Employees and Job Applicants

Last updated: April 25, 2023

This California Employee Privacy Notice (the “California Employee Privacy Notice”) supplements the NEW ID Privacy Notice and California Consumer Privacy Notice and applies to the personal information of California employees, interns, contractors, volunteers, and applicants for those roles collected by NEW ID LLC and its affiliates (collectively, “NEW”, the “Company”, “We”, “Our”, or “Us”). This California Employee Privacy Notice also applies to information provided to us about employees’ relatives or others that is used for emergency contact or benefits administration purposes.

Please read this California Employee Privacy Notice to learn how we collect and process your personal information when you are employed by NEW, engaged to provide services to NEW or apply for a job with NEW. Under the California Consumer Privacy Act of 2018, Cal. Civ. Code §1798.100 et seq. and its implementing regulations (the “CCPA”), as modified by the California Privacy Rights Act (the “CPRA”), you have he right to know and understand the categories of personal information we collect about you, and the purposes for which we use such personal information. Certain terms used in this California Employee Privacy Notice have the meaning given to them in the CCPA or CPRA and their implementing regulations. This California Employee Privacy Notice only applies to employees, contractors and job applicants who are residents of the State of California. NEW does not sell or otherwise disclose this personal information for monetary or other consideration to any third parties.

Personal Information We Collect

For purposes of this California Employee Privacy Notice, personal information means any information about an identifiable individual collected in connection with the recruitment process. We may collect personal information directly from you, as a job applicant, or may receive personal information from third parties, for example, in connection with a background, employment, or reference check, subject to your consent where required by law. Personal information excludes anonymous or de-identified data that is not associated with a particular individual.

We may collect, store, and process the following categories of personal information in connection with our recruiting activities:

At the initial stages of recruitment.

We may collect, hold and use the following types of personal information about you:

Information contained in your application form/resume/cover letter, including your name, title, contact details, employment history, experience, skills, qualifications/training (including educational, vocational, driving licences where appropriate), referees’ names and contact details, etc.
Publicly available information about you, such as your business social media presence (including any of photographs of you posted to such site(s)).
Selection information, including correspondence, interview notes, internal notes, the results of any written or online selection tests.
Equal opportunities monitoring data which could include information about your race or ethnicity, religious beliefs, sexual orientation or health. We only use this information to monitor equality of opportunity and diversity in our recruitment process.
Information relevant to any request by you for accommodations to the recruitment process as a result of an underlying medical condition or disability. We may use this information to enable us to carry out a fair, non-discriminatory recruitment process by considering/making reasonable adjustments to our process as appropriate.
Any additional personal details that you otherwise voluntarily provide to us.

If you receive a conditional offer of employment.

We may collect, hold and use the following additional types of personal information about you:

Pre-employment check information, including references and verification of qualifications.
Right to work checks and related documents.
Medical test results.
Driving test results/driver motor vehicle records (if applicable to proposed line of work)
Information about your health or mental state in a pre-employment medical questionnaire and/or examination, as well as any information about underlying medical conditions and adjustments that you have brought to our attention. We use this information to assess whether you are fit to do the job with adjustments, to consider/arrange suitable adjustments and to comply with health and safety requirements.
Criminal records information (if applicable to your line of work). We use this information to assess your suitability for the role and verify information provided by you.
Any additional personal details that you otherwise voluntarily provide to us (including personal information provided on your resume).

Source of Personal Information

We collect personal information you voluntarily provide to us during the application process or when you otherwise contact us. We may also automatically collect certain information, such as IP address and device identifiers.

We may combine personal information you voluntarily provide to us with information we collect from other sources, such as:

Recruiters;
Prior employers and professional references;
Educational institutions;
Pre-employment screening and background check services;
Credentialing and licensing organizations;
Publicly available sources, such as public social media profiles on LinkedIn, Twitter or Facebook; and
Other sources as directed by you

Business Purpose for Collecting Personal Information

We use the categories of personal information above for the following business purposes:

Recruitment of Employees and Processing and Managing Job Applications.

We use your personal information to process your job application, create an applicant profile, evaluate your qualifications, schedule and conduct interviews and communicate with you.

Conducting Pre-Employment Screening and Background Checks.

In accordance with applicable laws, we use your personal information to conduct employment screening and background checks.

Compensation and Expense Management.

We use your personal information to conduct payroll processing, salary administration, expense reimbursement, manage the Company’s corporate credit card program and other compensation purpose such as determining bonuses, equity and other forms of employee compensation.

Benefits Administration.

We use your personal information we collect to administer benefits we provide, such as medical, dental, vision, disability insurance, retirement benefits and other employee benefit programs.

General Human Resources Management.

We use your personal information we collect to provide general HR management services, including managing employee on-boarding, termination and separation, travel administration and return-to-work screening (including any medical screening as required or permitted by applicable law).

Training and Professional Development.

We use your personal information to provide employment-related training, assisting with professional licensing and development.

Internal Employment Purposes.

We use your personal information to conduct internal investigations, conduct surveys, resolve disputes, prevent or detect fraud or security incidents, conduct employee performance reviews, enforce our policies and code of conduct, protect the rights and safety of employees or others and manage whistleblower programs.

Compliance with Legal Requirements and Enforcement of Our Legal Rights.

We use your personal information to comply with applicable laws, regulations and legal processes (such as responding to subpoenas or court orders), and to respond to legal claims, resolve disputes, enforce our legal rights contained in employment or other contracts and comply with legal or regulatory recordkeeping requirements.

Disclosure of Personal information

We may share your personal information for the business purposes described in this California Employee Privacy Notice with the following parties:

Affiliates and Subsidiaries.

We may share your personal information with our affiliates and subsidiaries.

Service Providers.

We may share your personal information with service providers, such as recruiters, pre-employment screening services, third-party benefits administrators, payroll processors, background check providers and others.

Governmental Authorities.

As required by law or legal process, we may share your personal information with federal or state regulatory agencies, law enforcement, courts and other governmental agencies.

Professional Advisors.

We may share your personal information with our professional advisors, such as auditors and law firms.

Parties Involved with Business Transfers.

We may share your personal information to third parties in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).

In accordance with our policies and procedures, we will not discriminate or retaliate against you if you choose to exercise any of your rights under the CCPA or CPRA.

Change to Our Privacy Notice

This California Employee Privacy Notice will be updated at least once every twelve (12) months to reflect changes in our business, legal, or regulatory obligations. When we make changes to this privacy notice, we will notify you through a notice on our website homepage.

How to Contact Us

If you have any questions or concerns regarding this California Employee Privacy Notice or the collection of your personal information, please contact: privacy@its-newid.com.