CCPA Employee and Applicant Privacy Notice
University Instructors LLC (“UI,” “we” or “us”) adopts this California Consumer Protection Act Employee and Applicant Privacy Notice (the “Notice”) to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this Notice, unless otherwise defined herein. This Notice applies solely to all job applicants, employees, owners, directors, officers, and contractors who reside in the State of California (collectively referred to in this Notice as “California Workers”).
We are committed to protecting the privacy and security of the information we collect and to being transparent about the purposes for which we use your information. This Notice sets forth UI’s policies and practices for handling the information we collect and use in the employment context.
This Privacy Notice does not form any contract of employment for any contractors nor modify the employment terms to any candidates hired by UI.
1. Definitions
“Personal Information” or “PI” has the meaning as defined in the CCPA and includes information that is collected by UI about you in the course of your application for employment, direct services pursuant to a contract, or other employment-related purposes and encompasses any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.
“Process”, “processed” or “processing” means any operation or set of operations which is performed on Personal Information, whether or not by automated means, such as collecting, recording, organizing, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, disseminating or otherwise making available, aligning or combining, restricting, erasing, or destroying of Personal Information.
“Employees”, “employee” or “you” means an identified or identifiable natural person who is a California resident and who is acting as a UI job applicant, employee, owner, director, officer, or contractor. In this context “job applicant” refers to any person who has submitted their candidacy with UI; “employee” refers to any person who is employed at UI as a full or part-time employee or temporary worker; and “contractor” means a natural person who provides any service to UI pursuant to a written contract directly with UI.
2. Categories of Personal Information We Collect and Purpose of Collection
When a person applies to join the UI team or over the course of a person’s employment for or service with UI pursuant to a direct contract, 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.
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Categories of Personal Information Collected |
Purposes Personal Information is Used |
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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.
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· 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 |
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Protected classification information. This category includes characteristics of protected classifications under California or federal law, including 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
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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
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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 |
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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/her/their 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 |
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Education information. This category includes education history and transcripts that are not publicly available. |
• Evaluate an individual’s appropriateness for hire or promotion to a new position |
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Financial Information.
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• Process payroll • Manage company expenses, corporate credit cards and expense reimbursements, as well as administering equity, compensation, bonus, and insurance programs |
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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 |
3. Updates
This Notice may be changed to reflect changes in our business, legal, or regulatory obligations, so please check this Notice periodically for changes. To the extent UI intends to collect additional categories of your Personal Information or use your Personal Information already collected for additional purposes UI will notify you by providing an updated CCPA Employee and Applicant Privacy Notice. Any changes to this Notice will be effective from the date they are communicated to you.
4. Further Information
If you have any questions about this Notice, please contact:
Privacy Officer
University Instructors
Post Office Box 3074
Staunton, VA 24402-3074
ui@pcgus.com
1-800-210-6113
To carry out the purposes outlined above, UI may share information with third parties, such as background check vendors, third-party human resources and information technology vendors, outside legal counsel, and state or federal governmental agencies. UI may add to the categories of PI it collects and the purposes it uses PI. In that case, UI will inform you of those changes by providing an updated CCPA Employee and Applicant Privacy Notice.
If you have questions about the UI privacy policies and procedures, rights you may have regarding your Personal Information, you may contact UI’s Privacy Officer at 1-800-210-6113 or review our California Employee Privacy Policy. If you would like to exercise your rights to make a request about your Personal Information under the CCPA, please make a CCPA Employee Request via email at ui@pcgus.com.
LAST UPDATED: December 20, 2022