In accordance with the California Consumer Privacy Act (“CCPA”), we are providing additional information in this California Applicant Privacy Notice (the “California Notice” or “Notice”) to further describe the personal information that we collect about California job applicants (“California Applicants”). We may provide you with additional notices about our data collection practices that are covered by other laws (e.g., if we conduct a background check or extend an employment offer), as this Notice is limited to covering the requirements of the CCPA. The Notice solely governs the collection, use, disclosure, and transfer of personal information that we collect at the site and through the job application process; this Notice does not apply to any other website operated by Vanguard.
What is personal information? In this Notice, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.
Are our practices the same for all Applicants? The categories of personal information we collect and our use of personal information may vary depending upon the position(s) or location, as well as the associated qualifications and responsibilities. The information in this Notice is intended to provide an overall description of our collection and use of personal information about California Applicants.
What Personal Information Do We Collect under CCPA?
Generally, we may collect the following categories of personal information (as set forth in the CCPA) about California Applicants:
- Name, Contact Info and other Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, Social Security number, driver’s license number, passport number, or other similar identifiers.
- Protected Classifications: characteristics of protected classifications under California or federal law such as race, color, sex, national origin, citizenship status, gender identity.
- Usage Data: internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement, as well as physical and network access logs and other network activity information related to your use of any company device, network or other information resource. See additional information below regarding site usage data.
- Geolocation Data: precise geographic location information about a particular individual or device.
- Audio/Visual Data: audio, electronic, visual, thermal, olfactory, or similar information such as CCTV images and photographs, and audio recordings (e.g., recorded interviews).
- Employment History: professional or employment-related information.
- Education Information: information about education history or background that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
- Profiles and Inferences: inferences drawn from any of the information identified above to create a profile about a resident reflecting the resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Use and Disclosure
How Do We Use Personal Information?
We may use the above categories of personal information for the following purposes:
- Management of Job Applications, Recruiting and Hiring. To review, assess, recruit, consider or otherwise manage applicants, candidates and job applications, including:
- Scheduling and conducting interviews;
- Identifying candidates, including by working with external recruiters;
- Reviewing, assessing and verifying information provided to conduct criminal and background checks, and to otherwise screen or evaluate California Applicants’ qualifications, suitability and relevant characteristics;
- Extending offers, negotiating the terms of offers, and assessing salary and compensation matters;
- Satisfying legal and regulatory obligations;
- Communicating with California Applicants regarding their applications and about other similar position(s) for which they may be interested;
- Maintaining California Applicant personal information for future consideration;
- In support of our equal opportunity employment policy and practices.
- Security and Monitoring. In order to monitor and secure our resources, network, premises and assets, including:
- Monitoring for, preventing and investigating suspected or alleged misconduct or violations of work rules;
- Monitoring for, preventing, investigating, and responding to potential fraud, security and privacy incidents;
- Providing and managing access to physical and technical access controls;
- Monitoring activities, access and use to ensure the security and functioning of our systems and assets;
- Securing our offices, premises and physical assets, including through the use of electronic access systems and video monitoring.
- Auditing, reporting corporate governance, and internal operations. Relating to financial, tax and accounting audits, and audits and assessments of our business operations, security controls, financial controls, or compliance with legal obligations, and for other internal business purposes such as administration of our records retention program.
- M&A and Other Business Transactions. For purposes of planning, due diligence and implementation of commercial transactions, for example mergers, acquisitions, asset sales or transfers, bankruptcy or reorganization or other similar business transactions.
- Defending and Protecting Rights. In order to protect and defend our rights and interests and those of third parties, including to manage and respond to employee and other legal disputes, to respond to legal claims or disputes, and to otherwise establish, defend or protect our rights or interests, or the rights, interests, health or safety of others, including in the context of anticipated or actual litigation with third parties.
- Compliance with Applicable Legal Obligations. Relating to compliance with applicable legal obligations (such as hiring eligibility, responding to subpoenas and court orders) as well as assessments, reviews and reporting relating to such legal obligations, including under employment and labor laws and regulations, Social Security and tax laws, environmental regulations, workplace safety laws and regulations, and other applicable laws, regulations, opinions and guidance.
- Other Business and Commercial Purposes. In addition, we may use the personal information we collect about Applicants for other purposes including conducting surveys and workforce analytics.
If you have any questions related to your personal information under CCPA, please email us at firstname.lastname@example.org.
Effective: January 2020