CCPA Privacy Disclosure

PRIVACY NOTICE TO CALIFORNIA JOB APPLICANTS

Bodega Bay Associates and/or any affiliated entities (collectively, the “Company” or “we”) provide this California Privacy Notice (“Notice”) to describe our privacy practices with respect to our collection of Personal Information as required under the California Consumer Privacy Act (“CCPA”). This Notice applies only to job applicants and candidates for employment who are residents of the State of California (“Consumers”) and from whom we collect “Personal Information” as defined in the CCPA. We provide you this Notice because under the CCPA, California residents who are job applicants qualify as Consumers. For purposes of this Notice, when we refer to Consumers, we mean you only to the extent you are a job applicant who resides in California.

1. Information We Collect From or About Job Applicants


We may collect Personal Information from you in a variety of different situations and using a variety of different methods, including, but not limited to, on our website, your mobile device, through email, in physical locations, through written applications, through the mail, and/or over the telephone. Generally, we may collect, receive, maintain, and use the following categories of Personal Information, depending on the particular purpose and to the extent permitted under applicable law:

CATEGORY EXAMPLES RETENTION PERIOD
Personal
Identifiers
Name, alias, postal or mailing address, email address, telephone number, social security number, driver’s license or state identification card number.

If hired, this data will be retained for duration of employment plus 5 years. If not hired, it will be retained for 4 years from when position is filled or the date we receive your information, whichever is longer.

Contact Information Home, postal or mailing address, email address, home phone number, cell phone number. If hired, this data will be retained for duration of employment plus 5 years. If not hired, it will be retained for 4 years from when position is filled or the date we receive your information, whichever is longer.
Account Information Username and password for Company accounts and systems, and any required security or access code, password, or credentials allowing access to your Company accounts. Username: permanent; Password or security code: while in use + 1 year.
Pre-Hire
Information
Information provided in your job application or resume, information gathered as part of background screening and reference checks, pre-hire drug test results, information recorded in job interview notes by persons conducting job interviews for the Company, information contained in candidate evaluation records and assessments, information in work product samples you provided, and voluntary disclosures by you. If hired, this data will be retained for duration of employment plus 5 years. If not hired, it will be retained for 4 years from when position is filled or the date we receive your information, whichever is longer.
Employment
History
Information regarding prior job experience, positions held, and when permitted by applicable law your salary history or expectations. If hired, this data will be retained for duration of employment plus 5 years. If not hired, it will be retained for 4 years from when position is filled or the date we receive your information, whichever is longer.
Education
Information
Information contained in your resume regarding educational history and information in transcripts or records of degrees and vocational certifications obtained. If hired, this data will be retained for duration of employment plus 5 years. If not hired, it will be retained for 4 years from when position is filled or the date we receive your information, whichever is longer.
Inferences Based on analysis of the personal information collected, we may develop inferences regarding applicant behavior, skills, abilities and aptitudes. If hired, this data will be retained for duration of employment plus 5 years. If not hired, it will be retained for 4 years from when position is filled or the date we receive your information, whichever is longer.
Mobile Device Security Information Data identifying a job applicant’s device accessing Company networks and systems, including cell phone make, model, and serial number, cell phone number, and cell phone provider. 2 years
Online Portal and Mobile App Access and Usage Information Where job applicant or candidate must create an account to apply for a job, collect the applicant’s username and password, account history, usage history, and any information submitted through the account. 2 years

Of the above categories of Personal Information, the following are categories of Sensitive Personal Information the Company may collect:

  1. Personal Identifiers (social security number, driver’s license or state identification card number, passport number)

Personal information does not include:

- Publicly available information from government records.

- Information that a business has a reasonable basis to believe is lawfully made available to the general public by the job applicant or from widely distributed media.

- Information made available by a person to whom the job applicant has disclosed the information if the job applicant has not restricted the information to a specific audience.

- De-identified or aggregated information.

2. How We Use Personal Information and Sensitive Personal Information

The Personal Information and Sensitive Personal Information we collect, and our use of Personal Information and Sensitive Personal Information, may vary depending on the circumstances. This Notice is intended to provide an overall description of our collection and use of Personal Information and Sensitive Personal Information. Generally, we may use or disclose Personal Information and Sensitive Personal Information we collect from you or about you for one or more of the following purposes:

1. To fulfill or meet the purpose for which you provided the information. For example, if you share your name and contact information to apply for a job with the Company, we will use that Personal Information in connection with your candidacy for employment
2. To comply with local, state, and federal law and regulations requiring employers to maintain certain records (such as immigration compliance records, travel records, personnel files, wage and hour records, payroll records, accident or safety records, and tax records), as well as local, state, and federal law, regulations, ordinances, guidelines, and orders relating to COVID-19.
3. To evaluate, make, and communicate decisions regarding your job application and candidacy for employment.
4. To obtain and verify background check and references.
5. To communicate with you regarding your candidacy for employment.
6. To evaluate and improve our recruiting methods and strategies.
7. To engage in lawful monitoring of job applicant activities and communications when they are on Company premises, or utilizing Company internet and WiFi connections, computers, networks, devices, software applications or systems.
8. To evaluate job applicants and candidates for employment or promotions.
9. To obtain and verify background checks on job applicants and to verify employment references.
10.To engage in corporate transactions requiring review or disclosure of job applicant records subject to non-disclosure agreements, such as for evaluating potential mergers and acquisitions of the Company.
11.To promote and foster diversity, equity, and inclusion in the workplace.
12.COVID-19 RELATED PURPOSES

a. To reduce the risk of spreading the disease in or through the workplace.
b. To protect job applicants and everyone else at Company workplaces from exposure to COVID-19.
c. To comply with local, state, and federal law, regulations, ordinances, guidelines, and orders relating to COVID-19, including applicable reporting requirements.
d. To facilitate and coordinate pandemic-related initiatives and activities (whether Company-sponsored or through the U.S. Center for Disease Control and Prevention, other federal, state and local governmental authorities, and/or public and private entities or establishments, including vaccination initiatives).
e. To identify potential symptoms linked to COVID-19 (including through temperature checks, antibody testing, or COVID-19 questionnaire).
f.  To permit contact tracing relating to any potential exposure.
g. To communicate with job applicants and other consumers (including employees and visitors to our workplace) regarding potential exposure to COVID-19 and properly warn others who have had close contact with an infected or symptomatic individual so that they may take precautionary measures, help prevent further spread of the virus, and obtain treatment, if necessary.

13. To evaluate, assess, and manage the Company’s business relationship with vendors, service providers, and contractors that provide services to the Company related to recruiting or processing of data from or about job applicants.
14. To improve job applicant experience on Company computers, networks, devices, software applications or systems, and to debug, identify, and repair errors that impair existing intended functionality of our systems.
15. To protect against malicious or illegal activity and prosecute those responsible.
16. To prevent identity theft.
17. To verify and respond to consumer requests from job applicants under applicable consumer privacy laws.

3. Sale/Sharing of Information to Third Parties

The Company does not and will not sell your Personal Information or Sensitive Personal Information for any monetary or other valuable consideration. The Company does not and will not share your Personal Information or Sensitive Personal Information for cross-context behavioral advertising.

4. Access to Privacy Policy
For more information, please review the Company’s Privacy Policy at California Privacy Policy | Woodside Hospitality Group.