Applicant Privacy Policy
The Privacy Policy describes how Veteran Benefits Guide (“VBG”) (“VBG,” “we,” “us,” or “our”) collect, store, use, and disclose Personal Information about you as a job applicant. This notice describes how we use that Personal Information, to whom we disclose it, how you can exercise your data choices, and how you can contact us. Your “Personal Information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.
California Residents: See the California Privacy Rights section below for important information about your Personal Information and rights under applicable state privacy laws.
Not in scope. This Privacy Policy does not apply to interactions with VBG outside of the job application context, such as browsing our website, working for us, or using our services. Please click here: https://www.vbg.com/privacy-policy to review our Privacy Policy and learn more about our privacy practices related to those types of interactions. We may also collect, generate, use, and disclose aggregate, anonymous, and other non-identifiable data which is not Personal Information subject to this Privacy Policy.
You may download a copy of this Privacy Policy below:
If you have any questions, or if you need to receive this Privacy Policy in a different format, please contact us at (866) 412-8135 or compliance@vbg.com.
Contents
- Categories of Personal Information We Collect
- Sources Of Personal Information
- Purposes for Collecting Personal Information
- How We Disclose Personal Information
- How Long We Keep Personal Information
- Security
- California Privacy Rights
- Contact Us
- Updates to Our Privacy Policy
Categories of Personal Information We Collect
We collect, and in the preceding 12 months have collected, the below categories of applicant Personal Information with your consent or as otherwise required or permitted by law.
- Personal Identifiers, such as 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, such as 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.
- Professional or Employment-Related Information, such as your employment history (i.e., your prior dates of employment, where you worked, and what jobs you previously held), including your resume.
- Education Information, such as your education history (e.g., where you went to high school or college, your highest level of education, etc.)
- Audio, electronic, or similar information, such as electronic messages, including emails and text messages that you use to communicate with us regarding your interest to work at VBG, and any voicemails you may leave for us.
Sources of Personal Information
We collect, and in the preceding 12 months have collected, 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.
Purposes for Collecting Personal Information
We use Personal Information for the following purposes:
- Recruiting and hiring. We use identifiers, professional or employment information, and educational information we collect from your application and through the application and 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 determining whether you are qualified for employment with us.
- Post-Offer Diligence. If you are given a conditional offer of employment, we may thereafter conduct a background check and, as a result, may use identifiers, professional or employment information, education information, and Characteristics of Protected Classifications under California or Federal Law as part of the background check process.
- Legal Compliance and Protection. We use identifiers, professional or employment information, Characteristics of Protected Classifications under California or Federal Law, and education information we collect to comply with mandatory government reporting requirements and applicable laws, our legal obligations, and in the defense of our company, property, and others through legal proceedings.
How We Disclose Personal Information
We disclose Personal Information in the following circumstances:
- Service Providers. We disclose Personal Information with service providers who support the operation of our business, including our background check vendors. In some cases, the service provider may directly collect the information from you. In the past 12 months, we have disclosed identifiers, Characteristics of Protected Classifications under California or Federal Law, education information, and professional or employment information to our service providers.
- Job References and Prior Employers. If you identify a reference and any other employer(s) as part of your application, we may disclose your Personal Information to them. In the past 12 months, we have disclosed identifiers and professional or employment information to other employers.
- Professional Advisors. We may disclose Personal Information to professional advisors, such as lawyers, bankers, tax consultants, auditors, and insurers, where necessary in the course of the professional services that they render to us.
- Government Entities. We disclose Personal Information with regulatory and government entities including government, administrative, law enforcement and regulatory agencies; tax authorities; and other public agencies or authorities if we think we should to comply with any applicable law, regulation, legal process or other legal obligation. This includes cooperating with law enforcement when we believe it is appropriate, obtaining legal remedies or limiting our damages, and enforcing or protecting our contracts, legal rights, or the rights of others, including by responding to claims against us.
- Other Reasons. We may disclose Personal Information for other reasons we may describe to you, including if you consent to the disclosure or direct us to disclose your information.
How Long We Keep Personal Information
To the extent permitted by applicable law, we 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. 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?
Security
We follow generally accepted industry standards to protect the Personal Information submitted to us and have implemented reasonable technical, organization, administrative, and physical measures to protect Personal Information. No method of transmission or method of electronic storage is 100% secure, however.
California Privacy Rights
If you are a California resident, this section applies to you.
California Consumer Privacy Act (“CCPA”), as Amended by the California Privacy Rights Act (“CPRA”).
Sale or Sharing of Personal Information. In the preceding 12 months, we have not “sold” or “shared” (as those terms are defined in the CPRA) any Personal Information (including sensitive Personal Information) to “third parties” as that term is defined in the CPRA.
Use or Disclosure of Sensitive Personal Information. 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 for purposes other than those permitted by law.
Your Rights Under the CPRA. Subject to certain exceptions and limitations, the CPRA affords California consumers the following rights:
- You have the right to request that we tell you (i) what Personal Information we have collected about you, (ii) the sources of that information, (iii) the purposes for collecting, selling, or sharing the Personal Information; and (iv) the categories of third parties to whom we disclose Personal Information.
- You have the right to request that we provide you with a copy of your Personal Information.
- You have the right to request that we delete the Personal Information we collected from you. We may not delete all of your Personal Information if one of the exceptions to the CPRA applies.
- You have the right to correct inaccurate Personal Information that we hold about you.
- You have the right not to be discriminated against for exercising your CPRA rights. We will not discriminate against you if you exercise any of your CPRA rights.
Exercising Your Rights. To exercise any of your rights, you may email us at compliance@vbg.com, call us toll-free at (866) 412-8135, to submit a request, or use our Contact Us webform. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. You can ask to appeal any denial of your request in the same manner through which you may submit a request.
You should provide us with your name, email address, phone number, and mailing address for all requests. We will verify your identity by matching our information regarding our job applicants against the information you provided. Failure to provide the foregoing information may prevent us from processing your request. If you have requested that we correct your Personal Information, we may contact you to request additional information about the Personal Information that you believe is inaccurate, including supporting documentation.
Authorized Agents. Your authorized agent may be able to make a request on your behalf. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent authorization to submit the request.