HR Privacy Notice for California Residents
Effective Date: July 1, 2020
1. Introduction
This HR Privacy Notice for California Residents applies to ESCO Technologies Inc. (“we”, “us”, “our”, or “Company”) if and to the extent that it is subject to the requirements of the California Consumer Privacy Act of 2018 and its implementing regulations (“CCPA”).
2. The Application of this Notice
This HR Privacy Notice for California Residents describes the types of personal information we collect about California residents who are job applicants, employees, independent contractors, emergency contacts of employees, and individuals related to employees for whom we administer benefits (collectively, “Covered Individuals”, or “you”).
An employee is responsible for providing this HR Privacy Notice to the employee’s emergency contacts and individuals related to the employee for whom we administer benefits.
3. Personal Information We Collect
When we discuss “personal information,” we mean information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual. Personal information does not include information that has been excluded from the scope of the CCPA, such as publicly available information from government records; de-identified or aggregated information; and certain categories of information governed by other sector-specific privacy laws.
In particular, we may collect the following categories of personal information about Covered Individuals:
| Category | Examples and Explanation |
| Identifiers. | We collect identifiers, such as name, alias, postal address, email address, account name, Social Security number, driver’s license number, or passport number. |
| Personal information subject to the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | We collect additional information, such as signature, Social Security number, physical characteristics or description, insurance policy number, education, employment, employment history, bank account or credit card number, other financial information, medical information, and health insurance information. Some personal information included in this category may overlap with other categories. For job applicants and independent contractors, we only collect certain of this information as required to process job applications, conduct employment screenings or checks, for government-required screenings or to process payments. |
| Protected classifications under California or federal law. | We collect information in protected classifications, such as age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). We generally only collect this information with respect to employees, but may collect this type of information of job applicants and independent contractors where required to process job applications, conduct employment screenings, tests or checks, or for government-required screenings. |
| Biometric information. | Employees can voluntarily provide health and exercise data by participating in benefit programs we offer, which are administered on our behalf by third parties. |
| Internet or other similar network activity. | We may collect information about an employee’s internet use in accordance with applicable laws and any applicable company policy. Our corporate websites are subject to separate privacy policies which govern the collection of personal information on such websites. |
| Geolocation data. | We collect information about physical location. |
| Sensory data. | We collect audio, electronic, visual, or thermal information, such as voice messages and video surveillance for security purposes at our facilities. |
| Professional or employment-related information. | We collect professional or employment-related information, such as job history or performance evaluations. We generally only collect this information with respect to employees and job applicants, but on occasion with respect to independent contractors as needed. |
| Non-public education information. | We collect non-public education records, such as grades and transcripts, per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). We collect this information with respect to employees and job applicants, but generally not independent contractors. |
| Inferences drawn from other personal information. | We may make inferences from information identified above about employees and job applicants that reflect preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. We collect this information, for example, where we perform personality or skills assessments. |
4. Use of Personal Information
We may use personal information we collect as described above for the purpose of carrying out and supporting human resource functions and activities and for one or more of the business or commercial purposes as described below.
- Human resources and recruitment, managing all aspects of our relationships with job applicants, employees and independent contractors, including paying wages, fees and expenses; performing screenings, checks and verifications; providing access to facilities; and where appropriate for job applicants and employees, for recruiting; evaluating applications; checking references; administering reviews, discipline, and grievance processes; providing benefits and health programs; and conducting opinions and surveys;
- Providing products and services to customers, such as processing or fulfilling orders and transactions;
- Legal compliance and protection, including investigating and respond to claims against us; pursuing legal rights and remedies; defending litigation and managing internal complaints or claims; responding to legal process; protecting against malicious, deceptive, fraudulent, or illegal activity and prosecution of those responsible; complying with internal policies and procedures; complying with applicable laws (e.g., tax, health and safety);
- Information technology and security, includingdetecting security incidents; debugging to identify and repair errors that impair existing intended functionality; monitoring the use of IT resources; performing data analytics; securing our facilities;
- Auditing, including auditing compliance and financial auditing;
- Business administration, including engaging in strategic planning and project management; maintaining records related to business activities, budgeting and financial management; undertaking internal research for technology development and demonstration, including without limitation to developing and improving our products, services and our websites; undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade or enhance the service or device;
- Acquisition and business transactions includingevaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding; and
- other uses as described to you when collecting your personal information.
We may direct you to provide your personal information to governmental authorities when necessary for you to obtain required licenses, certifications or authorizations, and in those cases we may observe or otherwise collect that personal information as required by those processes.
We may retain your personal information after your employment ends for any residual aspects of the purposes set out above.
5. Sources of Personal Information
We receive the categories of personal information listed above from the following sources:
- directly from you, such as when you complete forms, contact us or visit our facilities;
- affiliates and subsidiaries;
- service providers that provide goods and services to us or our affiliates, such as companies that perform background checks and credit checks or that administer assessments;
- internet websites, social media and similar digital sources; and
- government entities and regulatory authorities.
We may also receive your personal information from third parties in connection with a business transition such as a merger, reorganization, acquisition, or purchase of all or a portion of business assets.
6. Changes to this Notice
Just as our business changes constantly, this HR Privacy Notice for California Residents may also change. As soon as practical following any such change, we will provide you with an updated HR Privacy Notice for California Residents.
7. Questions or Complaints
If you have any questions about this Notice, or any concerns or complaints with regard to this HR Privacy Notice for California Residents or the administration of either, you can contact [email protected].
If you have a disability and need access to this Notice in an alternative format, please contact us.
