Applicant Privacy Notice at Collection
Overview
This Notice explains your rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CPRA”) (Cal. Civ. Code § 1798.100 et seq.). It helps you understand how Veteran Benefits Guide (“VBG”) collects and uses your Personal Information in compliance with the CPRA. In this Notice, the terms “Company,” ”us,” “we,” “VBG,” and “our” refer to VBG and its affiliates. “Applicant” or “you” refer to job applicants or candidates for employment with VBG.
Who This Notice Applies To
The CPRA provides a right to notice at collection for certain California residents, including those applying to work at VBG.
This Notice does not cover:
- Your interactions with VBG outside the job application and recruiting context, such as browsing VBG’s website or using our services. To learn more about how we collect and use information related to those types of interactions, please see our VBG Privacy Policy.
What We Collect
As described in greater detail below, we collect Personal Information in the following ways:
- Directly from You. We may collect Personal Information directly from you as part of the application and recruiting process, such as when you submit a job application and resume (whether directly to VBG, or through a recruiter or referral), are interviewed by us, or when you inquire about opportunities with us.
- From Third Parties. We may collect certain Personal Information about you from third parties. For example, this includes from vendors that run background checks and references you provide to us. Our employees may provide us with information about you in connection with any job interviews you have with us. We may combine information that we collect from different sources.
- Personal Identifiers. We collect your name, address, telephone number, signature, and email address from you during our recruitment processes. If you receive a conditional offer of employment from us, we will also collect your Social Security number and date of birth.
- Characteristics of Protected Classifications Under California or Federal Law. If you receive a conditional offer of employment, we may collect information concerning your race, national origin, disability, marital status, sex, age, citizenship or immigration status to establish your authorization to work in the United States, and veteran or military status if you provide this information to us.
- Professional or Employment-Related Information. During the recruitment process, we collect information about your employment history (i.e., your prior dates of employment, where you worked, and what jobs you previously held), including your resume.
- Education Information. We collect your education history from you as part of your application.
- Audio, electronic, or similar information. We collect electronic messages, including emails and text messages, that you use to communicate with us regarding your interest to work at VBG. We also collect any voicemails you may leave for us.
The following forms of data listed above constitute “Sensitive Personal Information”: Your Social Security number, race, citizenship or immigration status, and disability, if provided to us. We do not use or disclose Sensitive Personal Information, as defined by California law, for inferring characteristics or purposes other than those permitted by law.
How We Use the Information We Collect
We use the Personal Information we collect for the following purposes:
- Recruiting and Hiring. We use the personal information we collect from your application and the interview process to evaluate your qualifications and eligibility for employment. We do not consider any Characteristics of Protected Classifications under California or Federal Law as part of our determination of whether you are qualified for employment with us.
- Post-Offer Diligence. If you are given a conditional offer of employment, we may conduct a background check and, as a result, may use Personal Information as part of the background check process to verify your identity and your credentials, so as to facilitate the background check.
- Legal Compliance and Protection. We use the personal information we collect to comply with applicable laws, our legal obligations, and our defense of our company, property, and others through legal proceedings. For example, if you have a disability that necessitates a reasonable accommodation, we use personal information relating to your disability to facilitate the process of discussing potential accommodations.
Please note that some of the internally provided applications and services we make available to you also include integrations, references, or links to services provided by providers whose privacy practices differ from ours. If you provide Personal Information via these integrations, references, or links or allow us to disclose It to them, that information is governed by their privacy statements. Finally, we may share de-identified information in accordance with applicable law.
Additional Rights Under California Law
You may have certain rights under California law. This may include a right to access, correct, or delete your data, subject to applicable exceptions. For example, we may retain your application data to comply with legal obligations. To exercise your rights, contact us as described at the end of this notice or use the webform on our website to submit a request.
Under California law, we are required to tell Californians if we “sell” or “share” Personal Information as that term is defined by applicable law. Sell is defined under the law as disclosing personal information to a third party for monetary or other valuable consideration. Share is specifically defined under the law as well. Sharing means sharing Personal Information with a third party for cross-context behavioral advertising.
We do not “sell” or “share” applicant data (including Personal Information and Sensitive Personal Information) based on our understanding of those terms. You may have different rights if you interact with VBG in other ways. For example, if you use our website, visit our privacy policy for information collection and rights for website users. If you are also an VBG customer, the privacy policy on our website applies to our interactions with you as a customer.
This notice does not affect other rights you may have under the California Labor Code or similar laws.
How We Retain Your Personal Information
To the extent permitted by applicable law, VBG will retain your Personal Information for as long as reasonably necessary to fulfill the purposes for which it was collected, including to meet any legal, accounting, or other reporting requirements or obligations. For example, we retain Personal Information in accordance with our obligations under applicable labor and employment laws and as necessary to administer and carry out the application and recruiting processes. We use the following criteria to determine retention periods:
- How long the information is needed to provide our services and operate our business;
- Whether there are contractual or legal obligations that exist that require us to retain the information for a period of time;
- Whether any law, statute, or regulation allows for a specific retention period;
- Whether an individual has agreed to a longer retention period;
- Whether the data is considered to be sensitive data; and
- What was the expectation for retention at the time the data was provided to us?
How You Are Protected Against Discrimination
VBG will not unlawfully discriminate against you for exercising your rights under the CPRA. This commitment applies to all persons involved in our operations and prohibits unlawful discrimination by any company employee.
Disclaimer
Nothing in this Notice restricts VBG’s ability to:
- Comply with federal, state, or local laws;
- Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
- Cooperate with law enforcement agencies concerning conduct or activity that the business, service provider, or third party reasonably and in good faith believes may violate federal, state, or local law;
- Exercise or defend legal claims;
- Detect security incidents and protect against fraudulent or illegal activity and prosecute those responsible for such activity; or
- Transfer Personal Information as part of a merger or acquisition, dissolution, bankruptcy, or any other transaction in which a third party assumes control of all or part of the Company.
Changes To This Notice
This Notice is reviewed and updated annually to ensure it accurately captures our practices and procedures. In addition, from time to time, we may update this Notice to reflect changes required by law or our privacy practices or procedures. The effective date for this version is posted in the footer below.
Privacy Policy
See our Privacy Policy for Applicants.