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PRIVACY NOTICE FOR CALIFORNIA
ASSOCIATES & APPLICANTS

 

Morley Companies Inc. (the "Company," "Morley") collects, processes, and uses your personal information ("Personal Information"), including sensitive personal information ("Sensitive Personal Information"), during your recruitment process or as part of your employment relationship with Morley for human resources, employment management, benefits administration, health and safety, and business-related purposes, and to be in legal compliance. The Personal Information processed by Morley (which may be held on paper, in electronic format, or in any other format) may be subject to certain legal safeguards specified in applicable laws.

Information That We Collect

We collect Personal Information, which may include Sensitive Personal Information, from you when you provide it to us, such as when you communicate with us and submit information to us as part of the application process or in the course of your employment with Morley. The types of Personal Information we collect about you depends on your interactions with us (such as whether you are an employee or an applicant) and are described in more detail below.

Below are the categories of Personal Information we may collect and the purposes for which we intend to use this information:

  • Identifying information, such as your full name, gender, date of birth, and signature.
  • Demographic data, such as race, ethnic origin, marital status, disability, and veteran or military status.
  • Contact information, such as your home address, telephone numbers, email addresses, and emergency contact information.
  • Dependent or other individuals’ information, such as their full name, address, date of birth, phone number, and Social Security numbers (SSN).
  • National identifiers, such as SSN, passport and visa information, and immigration status and documentation.
  • Educational and professional background, such as your work history, academic and professional qualifications, educational records, references, and interview notes.
  • Employment details, such as your job title, position, hire dates, compensation, performance and disciplinary records, and vacation and sick leave records.
  • Financial information, such as banking details, tax information, payroll information, and withholdings.
  • Health and safety information, such as health conditions (if relevant to your employment), job restrictions, workplace illness and injury information, and health insurance policy information.
  • Information Systems (IS) information, such as your search history, browsing history, login information, and IP addresses on the Company’s IS and networks.
  • Biometric information, such as facial recognition, fingerprints, iris or retina scans, keystroke, or other physical patterns.
  • Geolocation data, such as time and physical location related to use of an internet website, application, device, or physical access to a Company office location.
  • Sensory or surveillance information, such as call monitoring and video surveillance.
  • Protected information categories listed in the California Customer Records statute (Cal. Civ. Code § 1789.80(e)), such as name, signature, SSN, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information, understanding that some Personal Information included in this category may overlap with other categories.
  • Protected classification characteristics under California and federal law, such as age (40 years or older), 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, and genetic information (including familial genetic information).
  • Profile or summary about an applicant/employee’s preferences, characteristics, attitudes, intelligence, abilities, and aptitudes.
  • Sensitive Information, such as SSN, driver’s license, state identification card, or passport number; account login, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; racial or ethnic origin, religious or philosophical beliefs, and genetic data.

Sources of Personal Information  

The above information is collected in the following methods listed below: 

  • Job applications (hard copy or electronic copy);
  • Resume(s)/curriculum vitae(s);
  • Information provided during job forums and recruitment events;
  • Information forwarded by recruitment agencies;
  • Information provided directly from employees;
  • Information provided by benefit and retirement plan providers;
  • Pre-employment screening services;
  • Pre-employment and employment testing services;
  • Publicly available sources such as your social media profile (e.g., LinkedIn, Twitter, and Facebook);
  • Performance reviews;
  • Disciplinary and/or corrective processes;
  • Third parties as necessary for providing you with benefits and ancillary services;
  • Training and certifications.

Note: The above information is received by Morley in various forms, including hard-copy and electronic form, delivered in person or via email, fax, website, social media, etc.  

Purpose of Processing 

Morley collects Personal Information to use or disclose as appropriate to:

  • Comply with all applicable laws and regulations.
  • Recruit and evaluate job applicants and candidates for employment.
  • Conduct background checks.
  • Manage your employment relationship with us, including for:
    • Onboarding processes;
    • Timekeeping, payroll, and expense report administration;
    • Employee benefits administration;
    • Employee training and development requirements;
    • The creation, maintenance, and security of your online employee accounts;
    • Reaching your emergency contacts when needed, such as when you are not reachable, or are injured, or ill;
    • Workers’ compensation claims management;
    • Employee job performance, including goals and performance reviews, promotions, discipline, and termination; and
    • Other human resources purposes.
  • Manage and monitor employee access to company facilities, equipment, and systems.
  • Conduct internal audits and workplace investigations.
  • Investigate and enforce compliance with and potential breaches of Company policies and procedures.
  • Engage in corporate transactions requiring review of employee records, such as for evaluating potential mergers and acquisitions of the Company.
  • Maintain commercial insurance policies and coverages, including for workers’ compensation and other liability insurance.
  • Perform workforce analytics, data analytics, and benchmarking.
  • Administer and maintain the Company’s operations, including for safety purposes.
  • For client marketing purposes.
  • Exercise or defend the legal rights of the Company and its employees, and affiliates, customers, contractors, and agents.

Disclosing Personal Information 

Morley may disclose your Personal Information for the business purposes identified above. We may disclose your information to the following types of entities and third parties:

  • Affiliates: We may share your Personal Information with our affiliates.
  • Service Providers: Morley may engage fulfillment companies, service providers, individuals, and agents. Such service providers perform services on our behalf. We reserve the right to provide Personal Information to such companies to the extent it may be necessary for them to provide services to or on behalf of Morley. Any such companies must agree to maintain the confidentiality of any Personal Information we may provide to them and are contractually obligated not to disclose or use it for any other purpose. Such companies may also collect Personal Information directly from you in connection with providing their services, and they will have the right to provide that Personal Information to us. Such other companies may not use your Personal Information for purposes other than providing services through or on behalf of Morley.
  • Law Enforcement or Other Lawful Authority: We may from time to time be required to provide information to law enforcement or other governmental authorities pursuant to a warrant, court order, or other lawful process for purposes of fulfilling our legal obligations under applicable law, such as (i) preventing, detecting, and investigating security incidents, and potentially illegal or prohibited activities; (ii) protecting the rights, property, or safety of you, us, or another party; (iii) enforcing any agreements with you; (iv) responding to claims; and (v) resolving disputes.
  • 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. 

We do not sell or share (in the context of cross-behavioral advertising, which means the targeting of advertising to an employee based on the employee’s Personal Information obtained from the employee’s activity across businesses, including distinctly branded websites, applications, or services) your Personal Information, including Sensitive Personal Information, and have not in the immediate 12 months. If we do, you will be notified of it prior to or at the point of such collection for those purposes and provided a link to opt out of the selling/sharing of your Personal Information. We do not use or disclose Sensitive Personal Information, other than for the business purposes permitted by law as described above.

Retention of Personal Information

Morley will retain your Personal Information and Sensitive Personal Information only as long as necessary to facilitate the business purposes described above, and as necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies. Morley will process and retain Personal Information of employees and prospective employees for as long as it is reasonably necessary. We may retain Personal Information of prospective employees beyond the recruitment process to the extent necessary to consider the prospective employee for future job openings at Morley.

You may request that Morley remove your Personal Information at any time by emailing your request to ca-data-request@morleynet.com.

Monitoring

It may be necessary for us monitor our staff in various ways for safety and security and to protect our staff. We monitor our staff in the following ways:

  • Camera surveillance on all Morley properties;
  • Key Card and/or fingerprint-access entry onto and in certain Morley properties; and
  • Morley-owned computers and technical assets.

Your Privacy Rights

You have the following rights under applicable California law in relation to your Personal Information, subject to certain exceptions:

  • Right to Know and Right to Access: You have the right to, up to twice in a 12-month period, request what Personal Information we collect, use, disclose, share, and/or sell, as applicable. Specifically, you have the right to access any Personal Information that Morley processes about you and to request Information about:
    • The purposes for processing your Personal Information;
    • The categories of Personal Information concerned;
    • The recipients or categories of recipients to whom the Personal Information has been or will be disclosed;
    • The length of time Morley intends to store your Personal Information;
    • The specific pieces of Personal Information Morley has collected about you;
    • The source of information if Morley did not collect the information directly from you;
    • Whether we use automated decision-making (including profiling); and, if so, the logic involved and the intended consequences of such processing.

Upon your request, Morley will provide you with a copy of your Personal Information in a structured, commonly used electronic form.

  • Right to Delete: You have the right to request the deletion of your Personal Information that is collected by us.
  • Right to Opt Out of Sale: You have the right to opt out of the sale or sharing of your Personal Information by a business. However, as noted above, we do not currently sell or share any Personal Information.
  • Right to Limit Use and Disclosure of Sensitive Personal Information: You may have the right to direct us to limit its use and disclosure of your Sensitive Personal Information to that use which is necessary for the purposes stated above. As noted above, we do not use or disclose Sensitive Personal Information, other than for the business purposes permitted by law as described above.
  • Right to Non-Discrimination: You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.
  • Right to Correct: You have the right to correct inaccurate Personal Information that we maintain about you.

Information Subject Requests

You may submit a request to delete, correct, and/or to know by contacting us at 800.832.7368, or by emailing us at ca-data-request@morleynet.com, subject “California Data Subject Request.” Once we receive your request, we will follow up in no later than 10 days, confirm receipt of your request, and request information about you that we have collected, as set forth above, to allow us to verify your identity to ensure that you are submitting a request on behalf of who you say you are. You can also have an authorized representative submit a request on your behalf, but we must have proof that the person is indeed your authorized representative by seeing an authorization document that you have signed. This can include a Power of Attorney or other similar authorizing document.

For purposes of requests to delete, correct, and to know, we will verify your identity based on information we have collected about you, including your name, address, and phone number, but will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the consumer about whom we collected the personally identifying information on. If we are unable to verify your identity, we may deny your request.

We will respond to your request within 45 days after receipt of your request for a period covering 12 months and for no more than twice in a 12-month period. We reserve the right to extend the response time by an additional 45 days when reasonably necessary, provided that consumer notification of the extension is made within the first 45 days. We will give you notice of the reason for this additional time needed to process our request.

We do not charge a fee to process or respond to your verifiable consumer request, unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

These rights are also subject to various exclusions and exceptions under applicable laws.

We may also have to delay complying with a request to delete with respect to data stored on an archived or backup system, until such time as that system is restored to an active system, or is next accessed or used for sale, disclosure, or commercial purpose.

Security

Morley uses commercially reasonable security measures to prevent Personal Information from being accidentally lost, used, or accessed in an unauthorized way. We limit access to your Personal Information to those who have a genuine business need to know it. Those processing your Personal Information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Consequences of Not Providing Your Personal Information

You are not obligated to provide your Personal Information to Morley. However, as this information is necessary for Morley to employ you, Morley may not be able to extend an offer of employment or employ you without the provision of certain Personal Information.

Changes to the Privacy Notice

We have the right to unilaterally modify the Notice if this should become necessary due to changes in corporate practices regarding information processing, or changes in relevant laws and regulations, or changes in guidance and best practice documents issued by relevant authorities.  

Contact Us

If you have any questions about this policy or need to access this policy in an alternative format due to a disability, please contact
ca-data-request@morleynet.com and 800.832.7368.