California Privacy Policy for Employees and Job Applicants

Introduction

Populus Group ("Populus Group", "we", “our” or “us”) is committed to safeguarding your privacy.

Pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”), we are required to provide California employees and job applicants with a CA Privacy Policy that contains a comprehensive description of our online and offline practices regarding our collection, use, sale, sharing, and retention of their personal information as well as a description of the rights they have regarding their personal information. This California Privacy Policy for Employees and Job Applicants (“CA Privacy Policy”) provides the information the CCPA requires as well as other useful information regarding our collection and use of personal information.

Please review this CA Privacy Policy carefully. From time to time, we may change this CA Privacy Policy. If we do, we will post an amended version on our webpage and on our intranet policy page. You also may receive a copy at any time by contacting us at webmaster@populusgroup.com

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Accessibility

We are committed to ensuring this CA Privacy Policy is accessible to individuals with disabilities. If you wish to access this CA Privacy Policy in an alternative format, please contact us as at webmaster@populusgroup.com.

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Scope of California Privacy Policy

When This Policy Applies

This CA Privacy Policy is intended solely for, and is applicable only to, current and former California employees. Where relevant, it also applies to job applicants, interns, agency workers, contractors, consultants, directors, and other individuals whose information we collect in connection with providing employment. For ease of reference, this CA Privacy Policy generally refers to employee data, but this does not indicate in any way that an individual is our employee.

When This Policy Does Not Apply

This CA Privacy Policy only applies to individuals who are California residents.

If you are from California but you are not an Employees or Job Applicants (e.g., website visitors, customers, suppliers, and candidates), please see our California Notice at Collection for Non-Employees and Applicants

This CA Privacy Policy also does not apply to our collection and use of your personal information in a consumer or business-to-business capacity. For more information on our collection and use of your personal information in that capacity, including how we process opt-out preference signals, please see our online CA Privacy Policy available at https://www.populusgroup.com/en/privacy-policy

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California Notice at Collection of Personal Information

Personal Information We Collect

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified, or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this CA Privacy Policy, we will refer to this information as “Personal Information.”

While we provide this California Notice at Collection as part of this California Employee and Job Applicant CA Privacy Policy, you may also view the California Notice at Collection for Employees and Job Applicants as a stand-alone document here.

We currently collect and, in the 12 months prior to the Effective Date of this CA Privacy Policy, have collected the following categories of Personal Information from you (what we specifically collect will depend on where you are in the job applicant to employment lifecycle):

Identifying Information: such as your full name, gender, date of birth, marital status, employee ID number, signatures
Contact Information: such as your Email address, telephone number, postal address, and contact information for you and for your referrals, references, or emergency contacts.
National Identifiers: such as your SSN, Driver’s License Number, passport and visa information and immigration status and documentation
Dependents’ Information: such as your dependents’ and their respective names, address, date of birth and Social Security Number (SSN)
Educational and Professional Background: such as your work history, resume/CV, academic and professional qualifications and history, certifications, language proficiencies, awards, security clearance information, and other work-related skills
Employment Details: such as your job title, position, hire dates, base pay, bonus, commission, expense reimbursement, incentive pay and any other wage related information; performance and disciplinary records; timekeeping records including vacation and sick leave records; training records; and personality assessment information that you may take as part of the interview process or while you are an employee
Background Check Information: such as your background check, credit check, education verification, employment verification, and/or drug testing results (where you have provided consent for such screenings)
Benefits Administration Information: such as your benefits enrollment information, including Dependents’ Information you provide
Career Planning Information: such as your career interests, desired compensation and benefits, desired work location and willingness to relocate, family information you provide as it relates to your career goals or plans, hobbies and interests
Financial Information: such as your bank account routing and account information, tax information, payroll information and withholdings, and credit card information (for example if you choose to provide it for booking a hotel for work travel)
Health and Safety Information: such as your absence or leave records that contain health-related information (for example information about pregnancy, illness or other medical leaves of absence); information about your health as part of required occupational health screenings or related to a workplace injury; health information related to disability or other accommodation requests; health information related to COVID-19 symptoms, COVID-19 testing results, or COVID-19 vaccination status. Health information we hold about employees related to our self-funded medical plans is covered by our HIPAA Privacy Notice and not this Notice. You can obtain a copy of our HIPAA Privacy Notice from our intranet, our benefits website or by sending an email to webmaster@populusgroup.com.
Geolocation Information: such as time and physical location related to your logging into our network or applications or using your badge to enter one of our office locations.
Biometric Information: Your fingerprints (we will collect fingerprints only if we have provided you with a notice prior to collecting it that explains the reason for collection, which is usually for purposes of timekeeping or a security system). If a customer where you will be placed collects fingerprints, we will provide you with that information where we know it, but it is the customer’s responsibility to notify you since they are collecting the fingerprint.
Characteristics of Protected Classifications under California or Federal Law: Your race and national or ethnic origin, gender, and veteran status (for example in order to complete legally required EEO-1 or OFCCP reporting or other DEI company initiatives); disability status, information about religion (including religious dress and grooming practices and sincerely held religious belief, practice or observance), for example as part of a request for an accommodation; pregnancy and childbirth information (for example when you request FMLA leave or short-term disability); status as a victim of domestic violence, assault or stalking (if you request time off or an accommodation as allowed under law); union membership (if as part of working for one of our clients you are part of a union)
Audio, Visual or Similar Information: Photographs (for example for your security badge, your photo for our intranet or photos of you at company events), video interviews, IS help desk phone call recordings, WebEx/Teams video and audio recordings and video captured by our security systems.
Device Information: Your IP address, browser type and version, browser plug-in types and versions, operating system and platforms of the Allegis Group Electronic Resources (e.g., computers and other devices) you operate.
Other Information You Provide: including any other Personal Information you may elect to provide to us.

Sources of Personal Information

Information you submit to us: Where we request information from you, we will inform you prior to collection whether the provision of the Personal Information may be provided on a voluntary basis, and the consequences of not providing the information, which may include being unable to properly provide you with Services.
Information we obtain from other parties: We may receive or acquire information about you from other parties such as:

Websites and services like job boards and professional network sites (for example LinkedIn) and social media platforms and websites where you post information;
Clients (for example a client may provide current or prospective candidates for us to consider for a job they have asked us to fill);
o Business intelligence sources, including data aggregators and list providers;
o Your referrals and references (for example a referral who refers you to us for a potential job opportunity or a reference you provide to us);
o Trade journals and news sources (for example industry publications); and
o Populus Group affiliates, which are companies that have ownership in Populus Group, that are owned by Populus Group, or are under common control with Populus Group.

Any Personal Information you provide to a third party will be subject to that third party’s privacy notice and our use of the Personal Information we obtain from such third parties will be subject to this Privacy Notice.

We do not collect all categories of Personal Information from each source.

Purposes for Collection

We currently collect and have collected the above categories of Personal Information for all purposes of providing employment, including to:

Contact you for the purposes listed below. We may contact you by telephone, email, text messaging, or otherwise (note that messaging and data rates may apply for any SMS, MMS, and other electronic communications (typically, this is based on your carrier and service plan));
Comply with applicable local, state and federal laws and regulations;
Evaluate job applicants and candidates for employment;
Evaluate suitability for temporary assignments with our clients, to facilitate such assignments and address any issues that may arise from them;
Process payroll and/or travel and expenses;
Obtain and verify background, credit and education checks and/or drug testing as well as employment references;
Verify your ability to work in this country;
Track time and attendance at work;
Communicate with you regarding employment-related matters;
Communicate with your family or other contacts in case of emergency or other necessary circumstance;
Arrange business travel;
Establish and manage training, professional development and employee recognition programs;
Evaluate, make and communicate decisions regarding your employment, including decisions to hire, terminate, promote, demote, transfer, suspend or discipline;
Administer, manage and maintain benefits, including group health insurance, retirement accounts, short-term disability, and other Company benefits and perks;
Manage your job-related performance and/or employee conduct, including by engaging in lawful monitoring of your activities and communications;
Investigate and handle workplace investigations (such as investigations of workplace accidents or injuries, harassment or other misconduct), disciplinary actions or termination;
Administer and maintain our operations for safety purposes, including preventing the spread of illness and administer programs during a pandemic (e.g., COVID-19);
Implement, monitor and manage electronic security measures (including detection of security incidents);
Grant and monitor your access to secure company facilities;
Verify and respond to consumer requests under applicable consumer privacy laws;
Promote and foster diversity, equity and inclusion in the workplace;
Perform workforce analytics, data analytics and benchmarking;
Perform company audits;
Engage in corporate transactions requiring review of employee records and information, such as for evaluating potential mergers and acquisitions;
Maintain commercial insurance policies and coverages, including for workers’ compensation and other liability insurance, including managing workers’ compensation claims;
Evaluate, assess and manage the Company’s business relationship with vendors, service providers and contractors that provide services to the Company;
Improve user experience on Company computers, networks, devices, software applications or systems, and to debug, identify and repair errors that impair existing intended functionality of our systems; and
Exercise or defend our legal rights.

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Disclosure of Personal Information

The following identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Effective Date of this CA Privacy Policy and, for each category, categories of recipients to whom we disclosed Personal Information. For all of the Personal Information categories below except for Biometric Information, we may disclose, as appropriate under the circumstances, to government or law enforcement entities and lawyers.

Identifying Information and Contact Information: Clients and potential clients; vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as applicant tracking, back-office solutions, security vendors, data analytics providers, insurance vendors, company banks, benefits providers); Populus Group affiliates; auditors, consultants and other professional advisors
National Identifiers: Clients and potential clients; vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as applicant tracking and back-office solutions, security vendors, data analytics providers, insurance vendors, company banks, benefits providers); Populus Group affiliates; auditors, consultants and other professional advisors
Dependents’ Information and Benefits Administration Information: Vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as human capital solutions and back-office solutions, security vendors, insurance vendors, company banks, benefits providers); Populus Group affiliates; auditors, consultants and other professional advisors
Education and Professional Background: Clients and potential clients; vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as applicant tracking and back-office solutions, security vendors); Populus Group affiliates; auditors, consultants and other professional advisors
Employment Details and Career Planning Information: Clients and potential clients; vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as applicant tracking, human capital solutions and back-office solutions, security vendors); Populus Group affiliates; auditors, consultants and other professional advisors
Background Check Information: Clients and potential clients (where you have authorized releasee); vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as applicant tracking, human capital solutions and back-office solutions, security vendors); Populus Group affiliates; auditors, consultants and other professional advisors
Financial Information: Vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as human capital solutions and back-office solutions, security vendors); Populus Group affiliates; auditors, consultants and other professional advisors
Health and Safety Information: Vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as human capital solutions, security vendors); Populus Group affiliates; auditors, consultants and other professional advisors
Geolocation Information: Vendors, contractor and other service providers (e.g., badge entry information systems, security vendors); auditors, consultants and other professional advisors
Biometric: Not disclosed
Characteristics of Protected Classifications under California or Federal Law: Vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as human capital solutions, security vendors); Populus Group affiliates; auditors, consultants and other professional advisors
Audio, Visual or Similar Information: Vendors, contractors and other service providers (e.g., Company intranet system (for photos), video conferencing providers, security providers); auditors, consultants and other professional advisors
Device Information: Vendors, contractors and other service providers (e.g, IT operating and system and platform vendors; networking monitoring systems; security providers); auditors, consultants and other professional advisors

We disclosed Personal Information to the above categories of recipients for all of the business or commercial purposes identified in the above “Purposes for Collection” section.

We have not sold or shared Personal Information in the twelve (12) months preceding the Effective Date of this CA Privacy Policy.

We do not knowingly collect, sell, or share the Personal Information of individuals under 16 years of age.

We do not use Sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations.

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Retention of Personal Information

We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with services you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us. Please contact us as described in the “How to Contact Us” section below for more information on our employee data retention schedule.

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Your Rights

You have the following rights with respect to your Personal Information:

The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling, or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
The right to delete Personal Information that we collected from you, subject to certain exceptions;
The right to correct inaccurate Personal Information that we maintain about you;
If we sell or share Personal Information, the right to opt-out of the sale or sharing;
If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
The right not to receive discriminatory treatment by us for the exercise of privacy rights conferred by the CCPA.

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How to Exercise Your Rights

If you would like to exercise any of your privacy rights, please inquire here.

Call 248-712-7900 to submit your request.

If you are submitting a request on behalf of a California employee, please submit the request through one of the designated methods discussed above.

For all requests, after submitting the request, we will require additional information to reasonably verify your identity.

If you would like to update your personal information, such as to notify us of a change of name or address, or if you have questions about your employment, please contact your local Human Resources contact.

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Our Verification Process for Exercise of Your Rights

We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California employee on whose behalf you are making such request.

We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information involved in the request and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable.

For requests to access categories of Personal Information and for requests to delete or correct Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

For requests to access specific pieces of Personal Information or for requests to delete or correct Personal Information that is sensitive and poses a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

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Other Relevant Policies, Including Monitoring

When we hire you, we provide you with other policies and procedures that govern your use of our offices, networks, computers, and other devices. We have the right to monitor your use of our offices and electronic resources in accordance with those policies and procedures.
For more information, please read our Acceptable Use of Electronic Resources, Bring Your Own Device Policy, Personal Data Protection Policy, Social Media Policy, Workplace Monitoring Policy and our Employee Handbook. You can find copies of these policies on our intranet or by contacting your local Human Resources contact.

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How to Contact Us

To contact us for questions or concerns about our privacy policies or practices please email webmaster@populusgroup.com

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Changes to this California Privacy Policy and Effective Date

If we change this CA Privacy Policy, we will post the revised CA Privacy Policy on our Sites, with an updated revision date and distribute the new version to all employees upon hire. The Effective Date of this CA Privacy Policy is February 5, 2025.

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