This Privacy Addendum for California Employees and Job Applicants (the “California Employment Privacy Notice”) supplements the information contained in Foley & Lardner LLP’s (“Foley” or “we” or “us”) Employee Privacy Notice and applies solely to all staff, associates, partners, officers, and contractors of Foley (collectively, “Personnel”) and job applicants (“Applicants”) who reside in the State of California (“you”). We adopt this California Employment Privacy Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA that have the same meaning when used in this California Employment Privacy Notice.
Within the context of your role as Personnel or prospective Personnel, we will collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“personal information”). In particular, we will collect the following categories of personal information from employment applicant or our Personnel:
|Category||Types of Information|
|A. Identifiers||A real name, alias, postal address, email address, unique personal identifier, online identifier, Internet Protocol address (when you access our network resources), username, Social Security number, or other similar identifiers. If provided by you as proof of eligibility to work or as part of your business travel profile, driver’s license number or passport number.|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code §|
|A name, signature, Social Security number, address, telephone number, education, employment, employment history, bank account number, or health insurance information.|
If provided by you as proof of eligibility to work or as part of your business travel profile, credit card number, passport number, driver’s license or state identification card number.
Note: Some personal information included in this category may overlap with other categories.
|C. Protected classification characteristics under California or federal law.||NOTE: We require your age (40 years or older) and citizenship to verify your identity and to provide you with health and retirement benefits.|
You may also voluntarily disclose your race, color, ancestry, national origin, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, and pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status.
Foley is an equal opportunity / affirmative action employer and does not discriminate based on any of the foregoing (except as otherwise provided for by applicable law), or any other characteristic protected by applicable federal, state, or local law. Disclosure of this information is optional, and we will collect this information only to the extent you choose to provide it.
|F. Internet or other similar network activity.||Browsing history, search history, information on your interaction with a website or application.|
|H. Sensory data||Audio or visual information.|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.|
Personal information does not include publicly available information from government records, deidentified or aggregate consumer information, or personal information covered by certain sector-specific privacy laws, such as the Fair Credit Reporting Act and the Driver’s Privacy Protection Act of 1994.
EMPLOYEE NOTICE. As a self-funded insurer, Foley is subject to certain requirements under the California Confidentiality of Medical Information Act (CMIA) and Health Insurance Portability and Accountability Act of 1996 (HIPAA). We use a third party administrator to manage our self-funded insurance, so we do not receive or maintain your health or medical information. In the event we receive any information governed by the CMIA or HIPAA, such information is excluded from CCPA’s scope and is not considered personal information for the purposes of this California Employment Privacy Notice, but will be protected in accordance with those regulations.
IF YOU ARE AN APPLICANT, we may use or disclose the personal information we collect for one or more of the following business or commercial purposes:
IF YOU ARE PERSONNEL, we may use or disclose the personal information we collect for one or more of the following business or commercial purposes:
Regardless of whether you are Personnel or an applicant, Foley will not collect additional categories of personal information or use the personal information we collected for additional purposes without providing you notice.
Foley reserves the right to amend this California Employment Privacy Notice at our discretion and at any time. When we make changes to this California Employment Privacy Notice, we will post the updated notice on Foley’s website for Applicants, and on Foley’s intranet for Personnel. If you are Personnel, we may also notify you of any changes by email, internal memorandum, and/or posting on Foley’s internal websites.
If you have any questions or comments about this California Employment Privacy Notice and the ways in which Foley collects and uses your information described above or in the Employee Privacy Notice, please do not hesitate to contact us at the appropriate contact below:
APPLICANTS may contact us at [email protected].
PERSONNEL may contact the HR Department at [email protected].