California Privacy Rights Notice for Job Applicants and Prospective Talent
Openly LLC (“Openly”, “we”) is committed to protecting the privacy and security of personal information of all individuals including job applicants and complying with the California Consumer Privacy Act (“CCPA”) effective January 1, 2020; and all data privacy and laws in the jurisdictions in which it recruits and hires employees.
Under CCPA, Openly is required to inform California residents who are our job applicants or prospective talent (together “job applicants”) about the categories of personal information we collect about you and the purposes for which we will use this information. This notice contains disclosures required by the CCPA and applies only to personal information that is subject to the CCPA.
Sources of Personal Information we Collect
We collect personal information about our job applicants who are California residents from the following sources:
We collect personal information that you provide when you apply for a job with Openly on our careers site. Openly uses Greenhouse as our application service provider. The information you provide to Greenhouse is handled in accordance with Greenhouse’s Privacy Notice, available here.
We also collect personal information from other sources where relevant for your application, such as employment research firms, recruiters, identity verification services, and information that you make publicly available on websites or social media platforms (for example, LinkedIn). In some circumstances (if permitted by applicable law), we may need to perform a background check relevant to your job, in which case we would receive the results of the background check from the provider. If we do so, we will provide you with notice regarding this use when we collect your personal information and your consent to the background check will be sought at that time.
Throughout the recruitment process, we may supplement your personal information in connection with the assessment of your application. For example, we may record the views of those considering your application about your suitability for the role for which you have applied and retain interview notes.
If you accept an offer from us, your personal information will be incorporated into and used as part of your employee record.
Categories of Personal Information we Collect
We collect the following categories of personal information about our job applicants who are California residents:
- Personal and online identifiers and contact information (such as first and last name, email address, or unique online identifiers)
- Characteristics of protected classifications under California or federal law (such as race or gender)
- Professional or employment-related information
- Education information
- Internet or other electronic network activity information, including device data and online activity data
- Any other information you provide (e.g., cover letter, resume, photograph, articles, and comments)
In certain cases we may ask you for additional information for purposes of monitoring equal opportunity and/or complying with applicable laws.
The information we request as part of the job application process is necessary to enter into a possible employment contract. Failure to provide this information may prevent us from evaluating or otherwise processing your application. If you are a U.S. resident, we also may ask for certain demographic information, such as your gender, ethnic background, veteran status and disability status. Providing this information is optional and is not required to apply for a job with Openly. This personal information will not be considered in evaluating applicants’ qualifications for employment with Openly.
How we use Job Applicants' Personal Information
We collect this information to hire the best qualified applicants and to comply with applicable employment laws.
We use and disclose the personal information we collect for our business purposes. These business purposes include, without limitation:
- Processing, evaluating, and communicating with you about your application, including to check references or your background, and communicate with you about other jobs that may interest you.
- Other business purposes as identified in the CCPA, which include:
- Auditing related to our interactions with you;
- Legal compliance;
- Detecting and protecting against security incidents, fraud, and illegal activity;
- Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
- Internal research for technological improvement;
- Internal operations;
- Activities to maintain and improve our business; and
- Other one-time uses.
How we Share Job Applicants' Personal Information
We do not sell your personal information or disclose your personal information to third parties for targeted advertising purposes.
We may share your personal information with other parties as necessary for the purposes described above. By way of example and not limitation, we may share your personal information with:
- Affiliates, such as our corporate parent, subsidiaries, and other affiliates under the control of our corporate parent, for purposes consistent with this Notice or to operate shared infrastructure, systems and technology.
- Company service providers, such as IT systems and support, information and physical security, background checks and other screenings.
- Government authorities, such as law enforcement and courts for compliance, safety and fraud prevention purposes.
- Business transfer participants, such as parties to transactions and potential transactions whereby we sell, transfer or otherwise share some or all of our business or assets.
- Professional advisors, such as accountants, auditors, lawyers, insurers, bankers, and other outside professional advisors.
You have privacy rights that allow you to submit the following requests:
- Information about how we have collected and used your personal information. We have made this information available to you without having to request it by including it in this Notice.
- Access to a copy of the personal information that we maintain about you. Where applicable, we will provide the information in a portable, readily usable format.
- Correction of personal information that is inaccurate or out of date.
- Deletion of personal information that we no longer need or are otherwise required to retain.
In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights.
To submit a request, please email us or write to us as provided below. We may ask for specific information from you to help us confirm your identity. You are entitled to exercise the rights described above free from discrimination.
You may empower an authorized agent to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws.
We have put in place security measures designed to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know and are subject to confidentiality obligations.
We retain your personal information only for as long as is necessary to fulfill the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws.
To determine the appropriate retention period for your personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we use your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Other Information About This Notice
This notice does not address, and we are not responsible for, the practices of any third parties, which have their own rules for how they collect and use your personal information. Our links to third party websites or services are not endorsements.
Alternative formats for employees with disabilities
Upon request, this notice is available in alternative formats, such as large print, braille, or audio. Please contact firstname.lastname@example.org, and an alternative format will be provided to you so you can access the information in this notice.
It is your responsibility to ensure that information you submit does not violate any third party’s rights. You should keep your personal information on file with the Company up to date and inform us of any significant changes to it.
For questions or concerns about Openly’s practices, please contact us at email@example.com.
ATTN: Privacy Officer
131 Dartmouth St, 3rd Floor
Boston, Massachusetts 02116
Email address: firstname.lastname@example.org
Phone number: 1-888-808-4842