California Employee Privacy Policy

University Instructors LLC (“UI”) respects the privacy of your personal information. This California Employee Privacy Policy (“Policy”) outlines the types of information that UI may collect from you, what we do with that information, and with whom we may share the information.

Scope

This California Employee Privacy Policy applies solely to job applicants, employees, owners, directors, officers, and contractors of UI who reside in the State of California (collectively referred to in this Policy as “California Workers”). 

This California Employee Privacy Policy applies to the Personal Information (as defined in the California Consumer Protection Act or “CCPA”) collected by UI from California Workers who are applicants and/or employees, in connection with their application for employment and their employment with UI. This Policy also applies to the Personal Information collected by UI from California Workers who are contractors in connection with their provision of services to UI. This California Employee Privacy Policy supplements the UI’s general internal Privacy Policy and the Website Privacy Policy. This California Employee Privacy Policy controls with respect to the management of the Personal Information of California Workers as defined herein.  This Policy does not apply to other personal information collected in connection with use of our websites or personal information collected in connection with the services that UI provides to its clients.  

Amendments

UI may amend this California Employee Privacy Policy from time to time. If we make changes to this Policy, we will post the amended version on the web, on our internal UI SharePoint Policy site, and in other locations as may be required, and we will notify you about such changes.

This California Employee Privacy Policy was last updated on December 20, 2022. 

Collection and Use of Personal Information

When a California Worker applies to join the UI team as an employee; works pursuant to a direct agreement with UI as a contractor; or provides services during the course of employment with UI, we may collect the following categories of Personal Information. UI collects and uses this Personal Information only as permitted or required by, and in compliance with, law. 

UI has collected the following Personal Information for the following purposes within the 12 months prior to the last update of this California Employee Privacy Policy:

Categories of Personal Information Collected

Purposes Personal Information is Used

Identifiers and Contact information.

This category includes name, alias and other names, address, telephone and/or mobile phone numbers, email address, date of birth, Social Security Number, driver’s license number or state ID card number, passport number, and other unique personal identifiers associated with you or your beneficiaries such as your spouse or child.

 

 

·   Collect and process employment applications, including confirming eligibility for employment, background and related checks, and onboarding

·   Process payment or payroll and employee benefit plan and program administration, including enrollment and claims handling

·   Maintain personnel records

·   Comply with record retention requirements required by law

·   Communicate with employees and/or employees’ emergency contacts and plan beneficiaries

·   Comply with applicable state and federal labor, employment, tax, benefits, workers’ compensation, disability, equal employment opportunity, unemployment claim information requests, workplace safety, and related laws

·   Prevent unauthorized access to or use of the UI’s property, including the information systems, electronic devices, network, and data

·   Ensure employee productivity and adherence to UI policies

·   Investigate complaints, grievances, and suspected violations of UI policy

·   Use in the event of a substantial corporate transaction, such as a merger, asset sale, or consolidation

·   Respond to valid requests for data pursuant to a subpoena, court order, legal process, law enforcement requests, legal claims, and government inquiries

·   Carry out our contractual obligations or enforce our rights arising from any contracts between us

Protected classification information.

This category includes characteristics of protected classifications under California or federal lawincluding the following: race, skin color, national origin, religion (includes religious dress and grooming practices), sex/gender (includes pregnancy, childbirth, breastfeeding and/ or related medical conditions), gender identity, gender expression, sexual orientation, marital status, medical condition (such as genetic characteristics, cancer or a record or history of cancer), disability (such as mental and physical including HIV/AIDS, or cancer), military or veteran status, request for family care leave, request for leave for an employee’s own serious health condition, request for pregnancy disability leave, and age.

·   Comply with applicable state and federal Equal Employment Opportunity laws

·   Design, implement, and promote UI’s diversity and inclusion programs

·   Investigate complaints, grievances, and suspected violations of UI policy

·   Administer the employee benefit plan and program design and administration, including leave of absence administration

 

Sign-in, device, internet or other electronic network activity information.

This category includes without limitation:

•   username and password, account name or number, and other online or device identifiers

•   all activity on UI’s information systems, such as internet browsing history activity, search history, intranet activity, email communications, stored documents and emails and information regarding interactions with websites and applications, our systems, and networks;

·   all activity on UI-provided communications systems including call logs, chat logs, and direct messages, application use on company systems, browsing and search history on UI systems, email communications via UI email systems, and other information regarding an Employee’s use of UI-issued programs, applications, and systems.

•   Facilitate the efficient and secure use of UI’s information systems

•   Ensure compliance with UI information systems policies and procedures

•   Comply with applicable state and federal laws

•   Prevent unauthorized access to, use, or disclosure/removal of the UI’s property, records, data, and information

•   Enhance employee productivity

•   Investigate complaints, grievances, and suspected violations of UI policies

•   Verify and maintain the quality, safety, and performance of our products and services, including product and service testing, research, and development

•   To monitor work-related software licenses and credentials, including provisioning software licenses for use in the course of an employee’s work-related responsibilities

 

 

Geolocation data.

This category includes badge access at UI offices.

•      Improve safety of employees, customers and the public with regard to access of UI properties and equipment therein

•      Preventing unauthorized access, use, or loss of UI property

•      Ensure employee productivity and adherence to UI policies

•      Investigate complaints, grievances, and suspected violations of UI policy

Professional and employment-related information.

This category includes without limitation:

•   data submitted with employment applications including, employment history, employment recommendations, etc.

•   background check and criminal history

•   work authorization

•   professional licenses

•   educational degrees

•   fitness for duty data and reports (upon return from a medical leave of absence)

•   performance and disciplinary records

•   salary and bonus data

•   benefit plan enrollment, participation, and claims information

•   leave of absence information including religious and family obligations, physical and mental health data concerning employee and his or her family members

•      Collect and process employment applications, including confirming eligibility for employment, background and related checks, and onboarding

•       Employee benefit plan and program design and administration, including leave of absence administration

•      Determine compensation, bonus, and other incentive programs

•      Maintain personnel records and comply with record retention requirements

•      Communicate with employees and/or employees’ emergency contacts and plan beneficiaries

•      Comply with applicable state and federal labor, employment, tax, benefits, workers compensation, disability, equal employment opportunity, workplace safety, and related laws

•      Business management

•      Prevent unauthorized access to or use of UI property, including UI information systems, electronic devices, network, and data

•      Ensure employee productivity and adherence to UI policies

•      Respond to client or potential client requests for proposals

•      Recruiting, retention, and promotion of employees

•      Manage professional development

•      Manage conflicts of interest

•      Investigate complaints, grievances, and suspected violations of UI policies

Education information.

This category includes education history and transcripts that is not publicly available.

•      Evaluate an individual’s appropriateness for hire or promotion to a new position.

Financial Information.
This category includes bank account, billing address, and information about your income and account balances.

 

•      Process payroll

•      Manage company expenses, corporate credit cards and expense reimbursements, as well as administering equity, compensation, bonus, and insurance programs

Inferences drawn from the personal information in the categories above.

This category includes any information drawn from any of the personal information categories referenced above to create a profile about an employee reflecting the employee’s characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

•      Engaging in human capital analytics, including but not limited to, identifying certain correlations about individuals and success on their jobs, analyzing data to improve retention, and analyzing employee preferences to inform department and HR Policies, Programs and Procedures.

We do not hire minors under 16 years of age, and as a result, we do not knowingly collect Personal Information from minors under 16 years of age.

UI does not sell, rent, or trade Personal Information.

UI does not transfer Personal Information outside of the United States.

Sharing of Your Personal Information

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.

  • Authorized third-party vendors and service providers. We may share your Personal Information with third-party service providers and vendors that help us with specialized services, including onboarding, employment-related background checks, payroll, tax withholding, benefits administration, employee education, leave administration, technology and information systems management and support, expense management, and/or compliance and legal support.

  • Corporate affiliates. We may share your Personal Information with our corporate affiliates that are subject to this Policy.

  • Legal purposes. We may disclose Personal Information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, health, safety, and security of UI, our affiliates, users, or the public.

  • Business transfers. We may share your Personal Information in connection with a substantial corporate transaction, such as a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.

  • With your consent or at your direction. We may share your Personal Information for other purposes disclosed to you at the time we collect the information or pursuant to your consent or direction.

Rights of California Workers under the CCPA

If you are a California Worker, you have the following rights with respect to the Personal Information UI holds about you: 

  • You have the right to request that we report to you how we collect, use, transfer, or sell your Personal Information.

  • You have the right to request that we delete your Personal Information.

  • You have the right to opt out of the sale of your Personal Information.  (Please note, however, that UI does not currently sell any Personal Information.)

  • You have the right to not receive discriminatory treatment for exercising any of these rights.

If you would like to exercise any of your privacy rights, please contact ui@pcgus.com.

Only you, or a person whom you authorize to act on your behalf, may make a request related to your Personal Information.

In making your request, you must:

  • Provide us with sufficient information that allows us to verify that you are the person for whom we collected Personal Information or an authorized representative of that person;

  • Describe your request with sufficient detail that allows us to understand the request.

We may need to contact you in order to clarify your request, confirm your identity, or collect more information in order to verify and respond to your request. If we are unable to verify your identity, UI will not disclose any specific pieces of Personal Information to you and will inform you that we cannot verify your identity. In the event your request is denied in whole or in part, we will inform you of the reason for such denial.

Disclaimer

Maintaining the security of your Personal Information is of utmost concern to UI. UI uses reasonable security measures to protect Personal Information from unauthorized access. However, no system can be absolutely secure. Consequently, you should not transmit through email or our website any health information or other information that you consider sensitive. UI cannot warrant the security of any data transmitted via email or through our website, and you do so at your own risk.

Questions

If you have any questions about this California Employee Privacy Policy, please contact:

Privacy Officer
University Instructors
Post Office Box 3074
Staunton, VA 24402-3074
ui@pcgus.com
1-800-210-6113