Employee-Applicant Privacy Notice
Age of Learning, Inc. CCPA Employee, Contractor, and Applicant Privacy Notice
Effective Date: January 1, 2023
Age of Learning, Inc. (“AofL” or “Company”) knows your personal privacy is very important to you. This California Employee, Contractor, and Applicant Privacy Notice (“Notice” or “Policy”) describes our practices in connection with the personal information that we collect from our employees, board of directors, job applicants, and independent contractors (collectively, “you”) located in California in connection with your employment or other engagement with the Company. Please note that AofL may, from time to time, update or change this Policy.
Summary of Key Points
- Personal Information, or PI, is defined in this Policy to mirror the text of the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act (CCPA) and means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
- Because the security of your personal information is important to us, we only ask for PI where it serves a business purpose and try to limit the collection of PI to only what is reasonably necessary to accomplish those purposes. We also use commercially reasonable physical, technical, and administrative security measures designed to safeguard all information collected by the Company.
CATEGORIES OF PERSONAL INFORMATION WE MAY COLLECT
The Personal Information that we collect, use, or disclose about you will depend on our relationship or interaction with you. During the past twelve (12) months, we may have collected the following categories of PI. The table below also lists the purposes for which we may collect, use, or disclose PI in the context of your application for employment, your employment with us, or your work with us as an independent contractor or board member. Please note that some of the data collection and uses described below may not apply to you. It’s also important to note, we do not collect each personal identifier listed as examples under each Personal Information Category. We will not collect additional categories of personal information or use the PI we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Personal Information Category
Identifiers, such as your full name, contact information, gender, date of birth, signature, Social Security number, driver’s license or state identification numbers, and similar information for your dependents and beneficiaries.
Business Purpose
Recruiting Process and Management: communicate with applicants; evaluate applicants’ qualifications or suitability for employment; pre- employment and criminal history background check; applicant reference checks; identification purposes; arrange and manage company- sponsored events; recordkeeping purposes; demonstrate applicants’ agreement to, or acceptance of, documents presented to them, e.g., offer letter, NDA, acknowledgment of employment application
Managing Employees/Workforce Administration: onboard new employees; set up and manage a personnel file; manage performance; administer and communicate compensation, bonuses, equity grants, other forms of compensation, and benefits (as permitted by law); manage vacation, sick leave, and other leaves of absence; track hours and attendance; monitor compliance with company policies; communicate with the workforce; plan and arrange work supplies and workspaces; fulfill recordkeeping and reporting responsibilities; resolve internal grievances and disciplinary issues; make business travel arrangements; to manage workforce-related emergencies; generally manage personnel and workforce matters
Managing Employees/Workforce Development: provide, evaluate, and manage training; evaluate job performance; training purposes or quality assurance with respect to company employees; internal personality assessments used to facilitate conversations between individuals within the Company; analyze employee preferences to inform human resources policies and procedures; consider employees for internal positions or promotions; assist with professional licensing/certification; develop a talent pool and plan for succession and career development activities; conduct surveys, assist in receiving educational/vocational credit
Managing Employees/Workforce Team-building: maintain an internal workforce directory; purposes of identification; facilitate communication, interaction, and collaboration; arrange meetings and manage company- sponsored events and public service activities; promote the company as a place to work; workforce reporting and data analytics/trend analysis; workforce satisfaction; diversity and inclusion programs; arrange team- building and other morale-related activities; facilitate employee retention programs
Monitoring, Security, and Compliance: federal, state, and local jurisdiction regulatory and labor law compliance, contractual compliance obligations (e.g., criminal history background checks); recordkeeping; monitoring the use of information systems and other electronic resources or information systems; conduct internal audits; conduct internal investigations; protect the safety and security and control access to systems, equipment and facilities; monitor compliance with company policies
Conducting Our Business: human capital analytics, including to identify correlations about individuals and job success, analyze data to improve retention and productivity; travel and event planning; managing travel reimbursements; managing business expenses and reimbursements; engaging in marketing, advertising, and promotion; engage in crisis management; manage and operate information technology and communications systems, risk management and insurance functions, budgeting, financial management and reporting, and strategic planning
Health Information: to the extent necessary to comply with the company’s legal obligations, such as to accommodate disabilities; conduct a direct threat analysis in accordance with the Americans with Disabilities Act and state law (e.g., to test an individual for Covid); occupational health and safety compliance and record-keeping; workers’ compensation purposes; administer leaves of absence and sick time
Personal Information Category
California Customer Records employment and personal information, such as your name, signature, Social Security number, physical characteristics or description, photograph, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, current employment, employment history, membership in professional organizations, licenses and certifications, bank account number, credit card number, debit card number, or any other financial, medical or health insurance information.
Business Purpose
Same purposes as the “Identifiers” category
Personal Information Category
Protected classification characteristics under California or federal law, such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, reproductive health decision making, military and veteran status, or genetic information (including familial genetic information).
Business Purpose
Managing Employees/Workforce Administration: onboard new employees; set up and manage a personnel file; administer benefits (as permitted by law); fulfill recordkeeping and reporting responsibilities; resolve internal grievances and disciplinary issues; manage workforce- related emergencies
Monitoring, Security, and Compliance: comply with federal, state, and local jurisdiction regulatory and labor law compliance, contractual compliance obligations (e.g., criminal history background checks); recordkeeping; conduct internal audits; conduct internal investigations
Managing Employees/Workforce Team-building: to promote the company as a place to work, workforce reporting and data analytics/trend analysis; diversity and inclusion programs
Personal Information Category
Biometric information, such as fingerprints and certain wellness metrics.
Business Purpose
Recruiting Process and Management: pre-employment and criminal history background check; identification purposes
Monitoring, Security, and Compliance: contractual compliance obligations (e.g., criminal history background checks); notary services and requirements
Managing Employees/Workforce Team-building: to promote the company as a place to work, workforce reporting and data analytics/trend analysis; diversity and inclusion programs
Personal Information Category
Internet or other similar network activity information, including all activity on the Company’s information systems (such as internet browsing history, search history, intranet activity, email communications, social media postings, stored documents and emails, usernames, and passwords) and all activity on communications systems (such as phone calls, call logs, voicemails, text messages, chat logs, app use, mobile browsing and search history, mobile email communications, and other information regarding an employee’s use of company-issued devices).
Business Purpose
Monitoring, Security, and Compliance: federal, state, and local jurisdiction regulatory and labor law compliance, contractual compliance obligations; recordkeeping; monitor the use of information systems and other electronic resources or information systems; conduct internal audits; conduct internal investigations; protect the safety and security and control access to systems, equipment, and facilities; monitor compliance with company policies
Personal Information Category
Geolocation data, such as the time and physical location related to use of an internet website, application, or device.
Business Purpose
Monitoring, Security, and Compliance: monitoring the use of information systems and other electronic resources or information systems; conduct internal audits; conduct internal investigations; protect the safety and security and control access to systems, equipment, and facilities; monitor compliance with company policies
Personal Information Category
Sensory data, such as COVID-19 related temperature checks and call monitoring and video surveillance.
Business Purpose
Monitoring, Security, and Compliance: monitor the use of information systems and other electronic resources or information systems; conduct internal audits; conduct internal investigations; protect the safety and security and control access to systems, equipment, and facilities; monitor compliance with company policies
Personal Information Category
Professional or employment-related information, such as employment application information (work history, academic and professional qualifications, educational records, references, and interview notes, background check, drug testing results, work authorization, performance and disciplinary records, salary, bonus, commission, and other similar compensation data, benefit plan enrollment, participation, and claims information, leave of absence information including religious, military and family obligations, health data concerning employee and their family members.
Business Purpose
Managing Employees/Workforce Administration: onboard new employees; set up and manage a personnel file; manage performance; administer and communicate compensation, bonuses, equity grants, other forms of compensation, and benefits (as permitted by law); manage vacation, sick leave, and other leaves of absence; track hours and attendance; monitor compliance with company policies; communicate with the workforce; plan and arrange work supplies and workspaces;
fulfill recordkeeping and reporting responsibilities; resolve internal grievances and disciplinary issues; make business travel arrangements; to manage workforce-related emergencies; generally manage personnel and workforce matters
Managing Employees/Workforce Development: provide, evaluate, and manage training; evaluate job performance; internal personality assessments used to facilitate conversations between individuals within the Company; analyze employee preferences to inform human resources policies and procedures; consider employees for internal positions or promotions; assist with professional licensing/certification; develop a talent pool and plan for succession and career development activities; conduct surveys, assist in receiving educational/vocational credit
Monitoring, Security, and Compliance: federal, state, and local jurisdiction regulatory and labor law compliance, contractual compliance (e.g., criminal history background checks); recordkeeping; monitoring the use of information systems and other electronic resources or information systems; conduct internal audits; conduct internal investigations; protect the safety and security and control access to systems, equipment, and facilities; monitor compliance with company policies
Personal Information Category
Non-public education information, such as education records, degrees and vocational certifications obtained, report cards, and transcripts.
Business Purpose
Recruiting Process and Management: evaluate applicants’ qualifications or suitability for employment; pre-employment and criminal history background check; identification purposes; recordkeeping purposes
Personal Information Category
Inferences drawn from other personal information to create a profile or summary, for example, an individual’s preferences, abilities, aptitudes, and characteristics.
Business Purpose
Recruiting Process and Management: evaluate applicants’ qualifications or suitability for employment; applicant reference checks
Managing Employees/Workforce Development: provide, evaluate, and manage training; internal personality assessments used to facilitate conversations between individuals within the Company; analyze employee preferences to inform human resources policies and procedures
Conducting Our Business: human capital analytics, including to identify correlations about individuals and job success, analyze data to improve retention and productivity
Some of the personal information we collect from you may be considered “sensitive personal information.” We do not use sensitive personal information to infer characteristics about you. We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from your responses to information sought in your employee onboarding paperwork or forms you complete.
- Indirectly from you. For example, from observing your activities on company-provided software, including email accounts and computers, among other things.
- Third parties. For example, staffing and recruiting agencies with whom we contract for services and consumer reporting agencies when we perform employee background screenings.
PURPOSE FOR COLLECTING YOUR PERSONAL INFORMATION
In addition to the specific business purposes disclosed in the table above, we collect your Personal Information for the following general business purposes:
- To fulfill the reasons for which you provide us with the information;
- To comply with applicable law and regulatory requirements;
- To exercise the company’s rights under applicable law and to support any claim, defense, or declaration in a case or before a jurisdictional and/or administrative authority, arbitration, or mediation panel;
- To meet legal and regulatory requirements in connection with a corporate transaction including but not limited to a sale, or assignment of assets, merger, divestiture, or other changes of control or financial status;
- To manage licenses, permits, and authorizations applicable to Company’s business operations; protect the rights, property, or safety of the Company, employees, customers, or others; and
- For any other lawful purpose to further AofL’s legitimate interests.
HOW WE SHARE PERSONAL INFORMATION
We may disclose your personal information to a third party for the purposes described in this Policy, which include “business purposes” as defined under the CCPA. These business purposes may include processing your application, performing a background check, and providing your information to our Human Resources department or are service providers. When we disclose personal information for a business purpose, we will use reasonable commercial efforts to ensure that third parties keep your personal information secure, which may include entering a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We may disclose your personal information for a purpose described in this Policy to the following categories of third parties:
- Our affiliates or business partners.
- Service providers, including professional advisors, such as lawyers, auditors, and insurers, where necessary
in the course of the professional services that they render to us.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you, including but not limited to insurance companies and benefits providers.
- Government regulators and law enforcement or other third parties in connection with legal or regulatory requests.
- Buyers, advisors, potential transactional partners, investors, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, transfer, or license all or a portion of our assets in bankruptcy or otherwise. Please note that some of the categories described above may not apply to you.
In the preceding twelve (12) months, we have not sold any personal information.
RETENTION PERIOD
We retain your PI for as long as necessary for our business purposes and to comply with business, tax, and legal requirements, including without limitation, resolving disputes and enforcing our agreements. Retention periods vary depending on what the information is and what it is used for, and we decide how long we need PI on a case-by-case basis. We may consider the following factors when making retention decisions:
- Whether we are required by law to keep some types of personal information for certain periods of time to comply with our legal obligations, and
- Whether we need some of your personal information for other business purposes, such as investigating possible violations of any agreements we maintain with you to protect ourselves.
If we determine your personal information is no longer necessary using the factors above, we will generally delete or anonymize that information. We may retain anonymized, de-identified, and aggregate personal information indefinitely.
YOUR CCPA RIGHTS
The following sections disclose certain rights afforded to California residents by the CCPA. Any terms used but not otherwise defined in this Policy have the same meaning as defined in the CCPA.
- Access/Know. You can make a request about your PI that we collect or that we share for a business purpose through the self-service portal or by otherwise contacting us as described in this Policy. Prior to responding to your request, to verify such request, we will confirm your name, email address, and certain other necessary information based on the nature (e.g., sensitivity, amount, etc.) of the PI.
- Correct. You can make a request to correct your PI through the respective application storing your data (e.g., for employees, through our human resources management software (e.g., Dayforce)), or by otherwise contacting us as described in this Policy.
- Restrict/Opt-Out. You can make a request to restrict your sensitive PI (such as Social Security number) when there is no statutory exemption through the self-service portal or by otherwise contacting us as described in this Policy. We are not required to offer a right to limit our use or disclosure of sensitive PI where we perform the services reasonably expected by you (e.g., payroll and benefits).
- Delete. You can make a request to delete your PI when there is no statutory exemption to retain such PI (including, for example, an ongoing relationship, complying with a legal obligation, etc.) by contacting us or the relevant third party that collects and stores such PI (e.g., third-party background checks). Prior to responding to the request, to verify such request, we will confirm your name, email address, and certain other information necessary based on the nature (e.g., sensitivity, amount, etc.) of the PI.
We will not discriminate against you for exercising any of your data subject rights and do not charge a fee to process or respond to your requests unless it is excessive, repetitive, or manifestly unfounded.
HOW TO SUBMIT YOUR DATA REQUESTS
California residents may exercise their rights described above by submitting an inquiry via email using
hrprivacy@aofl.com or by reaching out to Human Resources either directly or through our employee self-service portal. You may authorize a third party to submit a data request on your behalf. Before we can comply with such a request, we will need to verify your identity, the identity of your designated agent, and the validity of your authorization to the agent to exercise your data rights. We endeavor to substantively respond to your data requests within 45 days of receipt and to your opt-out requests within 15 days. We will notify you if we require an extension. We may deny your request if we cannot verify your identity or the identity of your designated agent. In such case, we will inform you of such denial.