CALIFORNIA PRIVACY NOTICE TO CALIFORNIA EMPLOYEES AND CONTRACTORS REGARDING THE COLLECTION OF PERSONAL INFORMATION
This California Privacy Notice to California Employees and Contractors Regarding the Collection of Personal Information is solely meant for Europ Assistance North America California Employees and California Contractors (the “Privacy Notice”) who reside in the State of California (the “Employees”, “you” or ‘your”). Europ Assistance North America adopts this Privacy Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”).
ORGANIZATIONS COVERED BY THIS PRIVACY NOTICE
Europ Assistance North America is a family of companies, including (i) GMMI, Inc., (ii) Trip Mate, Inc., (iii) Customized Services Administrators, Inc. (iv) Generali Global Assistance, Inc. and (v) Generali US Branch. All references in this Privacy Notice to “Company”, “we“, “us” or “our” refer to Europ Assistance North America.
SCOPE OF THIS PRIVACY NOTICE
- In this Privacy Notice, when we talk about “Personal Information”, we mean information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Employee.
- You should be aware that Personal Information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA/CPRA’s scope, like:
- Protected Health Information under HIPAA, information subject to the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or
- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
WHAT CATEGORIES OF EMPLOYEE INFORMATION DO WE COLLECT AND HOW DO WE USE THIS INFORMATION?
We collect the following categories of Personal Information for the purposes described below:
|Category of Personal Data||Personal Information Collected||Purpose|
|Personal identifiers||Examples: ||The Company collects personal identifiers to onboard Employees; enroll and administer benefits; enter into contracts; and use for general human resource purposes.|
|Records identified by state law (including the California Customer Records statute (Cal. Civ. Code § 1798.80(e)))||Examples: |
The Company collects this information to process job applications; onboard Employees; enroll and administer benefits; enter into contracts; and use for general human resource purposes.
The Company collects pay information – such as pay rate, payroll deduction information banking information for direct deposit, and credit card information for expense reimbursement – to pay its Employees and comply with applicable laws.
|Protected classification characteristics under state or federal law||Examples: |
The Company collects equality and diversity information, such as minority, veteran and disability status, through voluntary self- disclosure and other means to implement the Company’s diversity programs and to comply with applicable laws.
The Company collects health and safety information to maintain a safe workplace; assess your working capacity; administer health and Workers’ Compensation insurance programs; and comply with applicable laws.
The Company also collects information necessary for benefits enrollment and administration purposes.
|Internet or other similar network activity information||Examples:||The Company collects this information to protect Company, customer, and Employee property, equipment and confidential information; monitor Employee performance; and enforce the Company’s Acceptable Use Policy.|
|Sensory data||The Company may collect audio and visual information of Employee through photographs used for identification purposes and to promote the Company. The Company collects audio and video recordings of training sessions.|
|Professional or employment-related information||The Company collects professional and employment- related information to manage its relationship with Employee.|
|Education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))||Examples:||The Company collects education information in connection with the job promotion process; to evaluate Employees for promotions; and to feature Employees in marketing materials and on the Company’s website.|
|Inferences drawn from other Personal Information||Examples:
||The Company may collect inferences drawn from other Personal Information to manage our relationship with Employee.|
|Personal Data about children under the age of 16||Personal Information about Employees’ dependents under the age of 16.||The Company collects information about Employees’ dependents under the age of 16 if Employees voluntarily provide such information in connection with the enrollment and administration of benefits and other human resource purposes that involve such dependents.|
|Legal and Contractual Information||Information necessary to: (i) respond to law enforcement and governmental agency requests; (ii) comply with legal and contractual obligations; (iii) exercise legal and contractual rights; and (iv) initiate or respond to legal claims||The Company collects this information to comply with legal and contractual requirements and to establish, exercise and defend legal and contractual rights and claims.|
|Emergency Contact Information||The Company collects this information to contact the Employee’s designated emergency contact persons in the event of an emergency.|
|Beneficiary Information||The Company collects this information to enroll and administer benefits programs for beneficiaries of Employees.|
SOURCES OF PERSONAL INFORMATION
We collect Personal Information directly from you. We may also combine Personal Information collected from other sources with the Personal Information you provide to us. For example, we may collect information from:
- Prior employers (e.g., for references)
- Professional references you provide to us
- Educational institutions
- Pre-employment screening services
- Credentialing and licensing organizations
- Publicly available sources such as your social media profile (e.g., LinkedIn, Twitter and Facebook)
- Third parties as necessary for providing you with benefits and ancillary services
- Other sources as directed by you
DISCLOSURE OF PERSONAL INFORMATION
We may share your Personal Information as necessary for the purposes described in this Privacy Notice. For example, we share your Personal Information with the following parties:
- Affiliates: We may share your Personal Information with our affiliates.
- Service Providers: We use service providers to operate, host and facilitate our operations and
business (including human resources operations). These include hosting, technology and communication providers; security and fraud prevention consultants; analytics providers; background and reference check screening services; and hiring process and benefits management and administration tools.
- Government authorities and law enforcement: In certain situations, we may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- Business transfers: Your Personal Information may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).
- Professional advisors: We may share your Personal Information with our professional advisors.
- Other: We may also share your Personal Information with third parties for purposes of fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, us or another party; enforcing any agreements with you; responding to claims; and resolving disputes.
RIGHTS AND CHOICES UNDER THE CCPA/CPRA
- Right to Access. You have the right to access your Personal Information that we may collect or retain about you. If requested, we shall provide you with a copy of your Personal Information that we collect as permitted under the CCPA/CPRA.
- Right to Know. You have the right to request that we disclose the following about your Personal Information, as defined under the CCPA/CPRA:
- The specific Personal Information we may collect;
- The categories of Personal Information we may collect;
- The categories of sources from which we may collect your Personal Information;
- The business purpose(s) for collecting or sharing your Personal Information;
- The categories of Personal Information we may disclose for business purposes; and
- The categories of third parties to whom we may share your Personal Information.
- Right to Deletion.
- You have the right to request that we delete any of your Personal Information that Company collected from you and retained, subject to certain exceptions. Any requests for deletion should be directed at firstname.lastname@example.org.; and
- Company may deny your deletion request for reasons permitted by the CCPA/CPRA. (i.e. if the information is excluded from the CCPA/CPRA or does not constitute Personal Information).
- Right to Correct. You have the right to request the correction of any Personal Information we maintain about you.
- Right to Limit Use or Disclosure of Sensitive Personal Information (“SPI”). You have the right to limit the use and disclosure of your SPI, if we are using your SPI beyond what is reasonable and proportionate to provide the requested goods or services.
- Response Timing and Format. Once verified the request is from a California consumer, Company will try to respond within 45 days. If we need more time, we will tell you in writing why and how much longer we need, either by mail or electronically (based on your choice).
- Non-Discrimination. Company will not discriminate against you for choosing to exercise any of your CCPA/CPRA rights, including with respect to any Company services.
UPDATING YOUR PERSONAL INFORMATION
It is important that the information contained in our records is both accurate and current. If your Personal Information happens to change during the course of your employment, please keep us informed of such changes. In some circumstances we may not agree with your request to change your Personal Information and will instead append an alternative text to the record in question.
HOW WE SECURE YOUR PERSONAL INFORMATION
We use appropriate technical and organizational measures to protect the Personal Information of our Employees. For example, we limit access to your Personal Information to members of Company’s and Company’s affiliates’ and subsidiaries’ personnel with a need to know in connection with their job duties, such as select personnel within the recruiting, human resources, finance, legal, insurance, information security and IT departments.
CHANGES TO THIS PRIVACY NOTICE
We may change this Privacy Notice at any time. Please check this Privacy Notice regularly to ensure that you are aware of any changes. We may try to notify you of material changes to this Privacy Notice, which if we do so may be by sending an email notification (if you have provided your email address to us), or by other reasonable methods.
INQUIRIES OR CONCERNS?
If you have any questions about this Privacy Notice or concerns about how we manage your Personal Information, please contact the Compliance Department (contact information below). We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you.
Attn: Customer Privacy Management Office
9797 Aero Drive, Suite 300
San Diego, CA 92123
Phone Number: 866-757-0010