Effective Date: January 1, 2023
This Notice describes how Evolve Treatment Center (together with its relevant subsidiaries, associates, and affiliated companies), “Company,” “we,” “us,” or “our”) processes personal information (“PI”) of Personnel (defined below) in various human resources (“HR”) contexts. This Notice is designed to meet obligations under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”). In the event of a conflict between any other Company policy, statement, or notice and this Notice, this Notice will prevail as to California Personnel, unless stated otherwise. Capitalized terms used but not defined in this Notice shall have the meanings given to them under the CCPA.
Applicability: This Notice applies to the following California residents who provided us with PI in HR contexts:
- Job applicants who have applied for a position with Company.
- Current/former employees of Company.
- Independent contractors of Company.
This Notice also applies to California residents whose family member or friend has provided PI about you to Company in an HR context, such as if:
- You are listed as an emergency contact for a Company employee or former employee.
- You are a beneficiary or dependent of a Company employee or former employee.
The individuals referred to in the foregoing bullet points are collectively referred to as “Personnel” throughout this Notice. Section 1 of this Notice provides notice of our data practices, including our collection, use, retention, and disclosure of Personnel PI. Sections 2-4 of this Notice provide information regarding California Personnel rights under the CCPA and how you may exercise them.
Non-Applicability: This Notice does not apply to our consumer facing website(s) or our other data practices outside of the human resources context, which are addressed in our general privacy notice available here.
1. Notice of Data Practices
The description of our data practices in this Notice covers the twelve (12) months prior to the Effective Date and will be updated at least annually. Our data practices may differ between updates, however, if materially different from this Notice, we will provide supplemental pre-collection notice of the current practices, which may include references to other privacy policies, notices, or statements. Otherwise, this Notice serves as our notice at collection.
A. PI Sources and Use
We may collect your PI directly from you, such as when you apply for a position or become employed or engaged by us (e.g., identification/identity data, contact details, educational and employment data), others through interactions in the course of employment or engagement, third parties (e.g., background check vendors and references), social media and professional networking services, or public sources of data.
Generally, we use Personnel PI for HR Business Purposes and as otherwise related to the operation of our business, including for: Performing Services; Managing Interactions and Transactions; Security; Debugging; Advertising and Marketing; Quality Assurance; Processing Interactions and Transactions; and Research and Development. For example, we use Personnel PI for the following purposes:
- Running background checks
- Employee intake/ onboarding/ off-boarding
- Maintaining personnel records
- Payroll, reimbursements, and timekeeping
- Processing leaves of absence
- Processing workers’ compensation claims
- Booking employee travel
- Benefits administration
- Employee activation initiatives and communications
- Facilitating diversity and inclusion programs
- Administering training and education programs
- HR IT systems and security
- Employee and performance management
- Health & safety/occupational health
- Security (including electronic and of premises)
We may also use PI for “Additional Business Purposes” in a context that is not a Sale or Share under the CCPA, such as:
- Disclosing it to our Service Providers, Contractors, or Processors that perform services for us (“Vendors”);
- Disclosing it to you or to other parties at your direction or through your action (e.g., payroll processors, benefits providers, some software platform operators, etc.);
- As required or permitted by applicable law;
- To the government or private parties to comply with law or legal process or protect or enforce legal rights or obligations or prevent harm;
- Where we believe we need to in order to investigate, prevent or take action if we think someone might be using information for illegal activities, fraud, or in ways that may threaten someone’s safety or violate our policies or legal obligations; and
- To assignees as part of an acquisition, merger, asset sale, or other transaction where another party assumes control over all or part of our business (“Corporate Transaction”).
Subject to restrictions and obligations under the CCPA, our Vendors may also use your PI for Business Purposes and Additional Business Purposes, and may engage their own vendors to enable them to perform services for us.
B. PI Collection, Disclosure, and Retention – By Category of PI
We collect, disclose, and retain PI as follows:
|Category of PI||Examples of PI Collected and Retained||Categories of Recipients|
||Real name, alias, postal address, unique personal identifiers, online identifier, Internet Protocol address, e-mail address, and account name.||Disclosures for Business Purposes:
||Name, signature, description, address, telephone number, and financial information (e.g., bank account number). Some PI included in this category may overlap with other categories.||Disclosures for Business Purposes:
||In some circumstances, we may collect PI that is considered protected under U.S. law, such as age, gender, nationality, race or information related to medical conditions, but only when that information is relevant for our Business Purposes. We abide by the legal requirements imposed under applicable law in regards to such information.||Disclosures for Business Purposes:
||Records of products or services purchased or obtained in the HR context, such as benefits you have signed up for.||Disclosures for Business Purposes:
||When you use our online systems or otherwise interact with us online, we may collect browsing history, search history, and other information regarding your interaction with our systems or other sites, applications, or content.||Disclosures for Business Purposes:
||If you use our systems or interact with us online we may gain access to the approximate, location of the device or equipment you are using, or the location from which you are accessing our systems.||Disclosures for Business Purposes:
||We may collect audio, electronic, or similar information via our video security recordings and call recording.||Disclosures for Business Purposes:
||Professional, educational, or employment-related information.||Disclosures for Business Purposes:
||Education records directly maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, schedules, identification codes, financial information, or disciplinary records.||Disclosures for Business Purposes:
||We may draw inferences from other information we collect about you. For example, based on your performance or other information we may recommend skills training that may benefit you.||Disclosures for Business Purposes:
||Government Issued ID Numbers (social security, driver’s license, state ID card, or passport number)||Disclosures for Business Purposes:
|Account Log-In (e.g., username and password to online account with Company)||Disclosures for Business Purposes:
|Financial Data (financial account number)||Disclosures for Business Purposes:
|Personal Characteristics (racial or ethnic origin or gender identity)||Disclosures for Business Purposes:
|Communication Content (contents of mail, email, and text messages, other than where Company is the intended recipient of the communication)||Disclosures for Business Purposes:
|Biometric Information (the processing of biometric info for the purpose of uniquely identifying an individual)||Disclosures for Business Purposes:
|Health Information (PI collected and analyzed concerning an individual’s health)||Disclosures for Business Purposes:
|Sex Life/ Sexual Orientation (PI collected and analyzed concerning an individual’s sex life or sexual orientation)||Disclosures for Business Purposes:
There may be additional information we collect that meets the definition of PI under the CCPA but is not reflected by a category above, in which case we will treat it as PI as required, but will not include it when we describe our practices by PI category. Because there are numerous types of PI in each category, and various uses for each PI type, actual retention periods vary. We retain specific PI pieces based on how long we have a legitimate purpose for the retention.
2. Your Rights and How to Exercise Them
California Personnel have the same rights to know/access, delete, correct, limit, and opt-out as traditional Consumers and may learn more about these rights and how to exercise them in Section 10(c) of our U.S. State Privacy Notice. You may also exercise your Consumer rights by calling us at (844) 384-6773.
Right to Limit Use and Disclosure of Sensitive PI
With regard to PI that qualifies as Sensitive PI under U.S. Privacy Laws, as of January 1, 2023, if you elect to provide us with that Sensitive PI, you can limit certain types of Sensitive PI Processing by following the instructions in the How to Exercise Your Consumer Privacy Rights section of our U.S. State Privacy Notice.
3. Non-Discrimination / No Retaliation
We will not discriminate or retaliate against you in a manner prohibited by the CCPA for your exercise of your privacy rights.
4. Our Rights and the Rights of Others
Notwithstanding anything to the contrary, we may collect, use, and disclose your PI as required or permitted by applicable law and this may override your rights under the CCPA. In addition, we are not required to honor your requests to the extent that doing so would infringe upon our or another person’s or party’s rights or conflict with applicable law.
5. Contact Us
If you have any questions, comments, or concerns about our HR privacy practices, please contact us by e-mail at [email protected] or call us at (844) 312-7376. Please note that e-mail communications will not necessarily be secure; accordingly, you should not include sensitive information in your e-mail correspondence with us.